GSP PWS QA 11AUG.xlsx
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- MHS EITS Geographic Service Provider (GSP) Federal contract opportunity
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- Defense Health Agency
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This special notice from the Defense Health Agency announces the development of the Military Health System Enterprise Information Technology Services Geographic Service Provider requirement. It will provide ongoing communication and solicit feedback to help define the GSP requirement. The notice includes a problem statement, general scope document, and list of potential GSP facilities. Responses to the initial data set are due by August 9, 2021 to christopher.d.rieper.civ@mail.mil. The DHA is also developing the Enterprise Information Technology Service Integrator and Capability Service Provider requirements. This special notice on sam.gov will evolve with new information to support all three related efforts.
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-1-2Q&A
| # | Basis of Award (-1) Reference | Proposal Instructions (-2) Reference | Technical Qualification Worksheet Reference | Concern /Question /Comment | Recommendation /Rationale | Govt Response | ASSIGNED TO | STATUS | CO OK | OGC OK | CO/OGC CONCERN NOTE |
| 1 | 1.6 Definitions | Would the Government please consider: |
1) expanding the recency definition to include projects within five years of the closing date of the solicitation?
2) accepting an original contract, combined with associated bridge contract(s), as one reference? 1) The Government appreciates this comment, however does not anticipate changes to this criteria. 2) Please see the definition of Recent in paragraph 1.6 of the Proposal Instructions which reads, " a project or contract where any contract performance having occurred within the three (3) years prior to the closing date of the solicitation. "
| 2 | Business Arrangement | If yes, do all CTA members require a secret level facility clearance? | All members of a JV must possess a facility clearance. In a prime/subcontract relationship, only the prime is required to possess a facility clearance. | |||
| 3 | Business Arrangement | Can the government clarify whether all team members (including subcontractors) require to have secret facility clearance? | All members of a JV must possess a facility clearance. In a prime/subcontract relationship, only the prime is required to possess a facility clearance. | |||
| 4 | Many of the requirements are very difficult for a small business. How is the government ensuring sufficient competition? | Based on Market Research the Government is confident there will be sufficent competition on this acquisition. | ||||
| 5 | 1.11 | If a referenced project covers multiple Volume II Scope areas, is only one CPARS or PPQ required to be submitted? | Clarification of submission materials | Each qualification identified shall have its own evidence file. If the evidence is identical, duplicate files shall be submitted with each applicable qualification. Please see updated instructions. | x | |
| 6 | 2.6.1.1, 2.6.3.1, 2.6.3.2 and others | When GSP Scope areas are referenced as a requirement as in 2.6.1.1., as well as other areas throughout the Basis of Award document, does this mean that the requirement has to be in a healthcare setting (DHA environment) or any IT contract that performed similar tasks? | Please clarify if when GSP scope areas are required that projects could be from any IT related project or must be from a DHA project. | Evidence is not limited to healthcare or DHA environments. | ||
| 7 | Business Arrangement | Since the opportunity is set aside for small businesses, can the government confirm whether or not large companies are allowed to sub to small business? | Large businesses may subcontract to a JV/team or Small Business offeror, provided the team also meets the requirements of FAR 52.219-4, Limitations on Subcontracting. | |||
| 8 | 2.6.1.3 | 1.8.3 | What is the government's intent in requiring small business to have a Multiple Award IDIQ? Would the government consider allowing sole source or single award IDIQs to be considered? |
Additionally, the values are inconsistent with small business IDIQ. See concern in F16. If the government is going to require experience in managing multiple award IDIQs then allow both competitive and sole source (direct award). There is no difference in the management of competitive or sole source multiple award IDIQs with multiple subcontracts. Both types of IDIQs should be considered.
| Similar to the recommendation in cell G16, we recommend lowering the $60M requirement to $8M. | No. The Government does not anticipate changes to this requirement. | |||
| 9 | 2.6.1.3 | 1.8.3 | Why is the government intent in requiring small business to possess a Multiple Award IDIQ? Would the government consider allowing sole source or single award IDIQs to be considered? |
| If management of a Multiple Award IDIQ is required we then also suggest allowing allowing both competitive and sole source (direct award). There is no difference in the management of competitive or sole source multiple award IDIQs with multiple subcontracts. We alsorecommend lowering the $60M requirement to $8M. | No. The Government does not anticipate changes to this requirement. | |||||||
| 10 | Addendum 52.212-2 - DRAFT GSP BASIS OF AWARD 13JUL 2022 | 2.2 | Is the government plan to award by geographic pools? For example, to have 3-5 companies receive awards at each geographic pool? | No. The Government anticipates a global MA IDIQ where Task Orders will be competed among all IDIQ holders for requirements globally. | ||||
| 11 | 2.6.1-2.6.4 | Attachment+8.DRAFT+GSP+TECH+QUAL+WRKSH+13JUL2022 | For Volumes II - V, there are several requested projects over the count of 1. e.g., up to 2, up to 3. In Areas that permit more than one project, the noted recommendation minimizes the ranking (and added evaluation) for some projects. | We suggest that the Government evaluate the highest rated project to meet the Satisfactory threshold rather than average or apply a weighting system in Areas where multiple projects are submitted. | Please note, the Basis of Award indicates, "The Government will evaluate Offeror’s qualifications on an Acceptable / Unacceptable basis only." The evaluation scheme does not include weights, averages, or rankings for evidence submitted. | |||
| 12 | 1.9 Volume III Scope Area Qualifications | SOWs and PWSs are not always fully representative of all of the work done on a project. Will the Government please clarify how they are going to evauluate relevancy / scope area qualifications as there may be no way to demonstrate a one-for-one requirement match between a contract document and the bulleted lists contained under each Scope Area within the DRAFT Proposal Instructions. | Please see paragraph 1.4 of the Proposal Instructions which indicates, "It is, therefore, the Offeror’s sole responsibility to identify specific page and paragraph number (e.g., columns E, G, or I of the GSP Technical Qualification Worksheet (Attachment X) within the evidence which substantiates the Offeror’s qualification.... Offeror shall align and narrow evidence to that which supports the identified qualification." It is the Offeror's responsibility to demonstrate to the Government that it has met the requirements of the solicitation. | |||||
| 13 | Section 1.8.1 | Paragraph 1.12 indicates that the government will assess proposals to determine if any information provides a reason to believe the offeror would likely offer other than fair and reasonable pricing”. Given there is no price evaluation at the base contract level how would this be assessed? | Please see paragraph 2.7 of the Basis of Award document for this information. | |||||
| 14 | 1.8.1 Volume II Support Quals - Multiple SubK Management | As PWSs or SOWs don't always contain evidence of managed subcontractors, will the Government accept a cover page or signature page of a subcontractor agreement for the referenced project as evidence to meet this requirement, or provide other examples of evidence that would be accepted? | Please see the definition of Evidence, which indicates: Information sufficient to support the reasonable belief that a particular act has occurred and directly links to the entity for which a qualification is being identified. For Support Area, Scope Area, and Geographic Breadth Qualifications, the following are considered evidence: referenced project award or execution document, including its Scope of Work (SOW)/Performance Work Statement (PWS) that cross references with Contract Line Item Numbers (CLINs). | |||||
| 15 | Section 1.8.1, Page 10 | Proposal instructions page 10, section 1.8.1, indicates that evidence submitted must include (among other requirements) “up to two (2) recent, referenced projects”. Question: what is the definition of recency that will be employed? | Please see the definition of Recent in the Proposal Instructions. | |||||
| 16 | 1.7.5, Past Performance Consent Letters | There is a requirement to attach and submit the consent letters to Volume I. Can the Government provide a template or required content for the consent letters? | Provide any required template or form contents that apply to bidders. | Please see updated verbiage in Section 1.7.5. | x | |||
| 17 | L.1.3 | Page count limitations are not defined in Section L. | Recommendation: Provide page count limitations in L or state explicitly there are no page count limitations for proposal volumes. | |||||
| Rationale: Clarity. | Please see updates in Section 1.5. | x | ||||||
| 18 | 2.6.2. VOLUME III –Scope Area Qualifications | Could the government please clarify the minimum contract value (obligated or funded) for the referenced projects to be used in the scope areas (1 through 7? | Scope Area Qualifications do not have a minimum contract value, only Support Area qualifications specify a minimum. | |||||
| 19 | 2.6 | The section states, "The Offeror must ensure all evidence is accurate, complete, and complies with the instructions herein and substantiates the identified qualification(s). Any identified qualification that does not have corresponding evidence will not be verified by the Government." | Notwithstanding the CPARS and past performance questionnaires (PPQ), is there additional information (i.e. Evidence) required to substantiate the CPARS and PPQ? | The CPARS or PPQ is the only evidence required for Past Performance Qualifications. | ||||
| 20 | 1.10.1 | Volume 4: Geographic Area 1: OCONUS, plus SOFA & DOCPER System. Would the Government consider adjusting the performance requirement to include SOFA and/or DOCPER processing experience. | Consistency and Robust Competition. The DOCPER requirement will limit competition to vendors with experience in NATO only and preclude vendors with targeted, highly relevant Indo-PAC experience. By expanding the requirement to SOFA and/or DOCPER, the Government will expand competition to include vendors with OCONUS experience in areas other than NATO, to include Indo-PAC. | The Government appreciates this comment and will make changes to the criteria accordingly. | x | |||
| 21 | 2.6.3 | (Section 2.6.3.1) states that to be evaluated positively past performances must be for: |
- Services were performed in one (1) or more of the following countries: Germany, Spain, Italy, United Kingdom, Turkey, Japan (including Okinawa Islands), or Korea.
- Services performed included experience staffing personnel in a country where SOFA status was granted and personnel processed through the DOCPER system.
| DOCPER is typically applicable for Germany and Italy. This means that vendors only operating in the other listed OCONUS countries would not meet the DOCPER requirement. | Recommendation: Revise the following sentence as " Services performed included experience staffing personnel in a country where SOFA status was granted and/or personnel processed through the DOCPER system." | The Government appreciates this comment and will make changes to the criteria accordingly. | x | |||
| 22 | M.2.6.3.1 | L.1.10.1 | Line 20 | L.1.10.1 and M.2.6.3.1 bullet 3 requires evidence showing "…personnel processed through the DOCPER system" to be considered a qualifying OCONUS project. DOCPER is not a System, but rather the US Army Europe and Africa - DOD Contractor Personnel (DOCPER) Office who are "...responsible for assisting contractors to receive status under NATO Status of Forces Agreements once they have been offered a contract." and appears to only apply to Italy and Germany. | Recommendation: Change L.1.10.1 and M.2.6.3.1 bullet 3 to read: "Services performed included experience staffing personnel in a country where SOFA status was granted." | |
| Rationale: As currently written, unless an offeror has a project in Germany or Italy, they cannot qualify for the OCONUS Geographic area, even if they have a project performing work in Spain, United Kingdom, Turkey, Japan or Korea (per bullet 2). Recommended change ensures companies can appropriately qualify as performing OCONUS work by not limited the Geography artificially through demonstration an offeror has gained accreditation for its contractors through the DOCPER office. Tighter restrictions can be placed on OCONUS locations at the task order level. | The Government appreciates this comment and will make changes to the criteria accordingly. | x | ||||
| 23 | 1.8.1 | Support Area 1 | ||||
| Row 5 | Concern: The GSP Incumbent Contract Data furnished with this draft solicitation lists 112 current contracts as in scope, of these 112 contracts, Zero have an Annual Value of $20M or greater, and 4 have a total contract value greater than $60M, where 2 of the 4 are being performed by Other Than Small Businesses. Of the two being performed by small business, 1 is at WRNMMC, the other is the Network Engineering & Support (NE&S) contract, being performed by a Mentor-Protege Joint Venture. WRNMMC has been a frequent target of public criticism from the MHS CIO/DHA J6 for its high costs and bloated staffing. It is difficult to understand why this contract (and presumably its predecessors) would be so privileged as the only direct MTF support contracts that qualify a company to perform as a Prime contractor. As such, it is not clear why the bar has been set at $20M/$60M as this threshold excludes 98% of current small business prime contract holders with no obvious benefit to the government. Lowering the threshold is also problematic, as it would heavily favor Alaskan Native, Native Hawaiian, and Tribal Native corporations at the expense of the rest of the small business community. The vast majority of the work in scope of this consolidation is being successfully performed by the same small business community which is excluded from bidding as a Prime contractor based on these requirements. | The GSP Incumbent Contract Data furnished with this draft RFP suggests that the methodology of setting an threshold for Annual Value or Total Contract Value may not be the best approach to identifying viable prime contractors, the government might consider a "point system" that measures the potential prime contractor's project experience by assigning points to project elements that are better determinants that have better links to future indicators of successful GSP performance (e.g., MTF project citations in multiple markets, supporting multiple Services, and supporting multiple sized MTFs). This diversity of experience on the part of the prime seems a far more important measuring stick to providing excellent service than simply performing on a large contract. |
In addition, recommend reducing the period of relevancy for past performance from 5 years to 3 years.
| We are happy to share our analysis of the FPDS.gov records with the government if this would be of use in expediting the market research supporting the ability of traditional small businesses to prime this contract. | The Government appreciates this comment and will make changes to the criteria relative to dollar thresholds. Please see updated Instructions to Offerors and Basis of Award for details. However, the Government does not anticipate changes to the recency. | x | ||||||
| 24 | Addendum 52.212-2 - DRAFT GSP BASIS OF AWARD 13JUL 2022 | 2.6.1.3 | The requirement for a Small Business to have one Multiple Award IDIQ contract project and the project to have an obligated or funded value greater than $60M total or $20 million in any one year significantly limits small business competition unless a small business JV with a large business member. Has this requirement remained as an oversight when this solicitation was originally considered to be full and open (unrestricted)? | Request the government to modify dollar thresholds to $25M total or $7M in any one year. | The Government appreciates this comment and will make changes to the criteria. Please see updated Instructions to Offerors and Basis of Award for details. | x | ||
| 25 | 1.8.1 Volume II Support Quals - Multiple SubK Management | As of May 2022, most of the incumbent contracts provided within "GSP Incumbent Contract Data as of 05APR2022" appeared to have a spend of $10M or less to date, and only two of the contracts appeard to have a spend of over $60M. Additionally, the scope of many of these incumbent contracts appear to only span 1 or 2 scope areas as defined within the PWS and/or Draft Proposal Instructions. Will the Government please consider modifying this requirement to require the project to meet at least 2 of the scope areas as defined, and a value that exceeds $10M total expected contract value? | The Government appreciates this comment and will make changes to the criteria. Please see updated Instructions to Offerors and Basis of Award for details. | x | ||||
| 26 | 1.8.3 MATOC IT IDIQ | As of May 2022, most of the incumbent contracts provided within "GSP Incumbent Contract Data as of 05APR2022" appeared to have a spend of $10M or less to date, and only two of the contracts appeard to have a spend of over $60M. Will the Government please consider modifying this requirement to require the project to meet a value that exceeds $10M total expected contract value? If not, would the Government please consider allowing subcontractors to meet this requirement? | The Government appreciates this comment and will make changes to the criteria. Please see updated Instructions to Offerors and Basis of Award for details. | x | ||||
| 27 | 1.8.3 | Support Area 3: Multiple Award ID/IQ Contract for DoD IT Services. Would the Government consider adjusting the project obligated or funded value to $10 million annually? | Robust Competition. The Government has stated it is looking for robust competition. If the projected obligated or funded values remain at $60 million total or $20 million in any one year, the Government is severely restricting small business competition. | The Government appreciates this comment and will make changes to the criteria. Please see updated Instructions to Offerors and Basis of Award for details. | x | |||
| 28 | 1.8.1 & 1.8.3 | The referenced projects shall each be within the recency period and have an obligated or funded value exceeding $60 million total or $20 million in any one year. | This is an unreasonable request for small businesses and exceeds the small business NAICS size standard listed at $32.5M. IDIQ which is over multiple years with a $20M award for a single year will exceed the annual receipts and average employment of a firm that can be found in 13 CFR 121.104 and 1.06. We request that the Government consider revising the dollar threshold to have an obligated or funding value exceeding $15 million total or $5 million in any one year. | The Government appreciates this comment and will make changes to the criteria. Please see updated Instructions to Offerors and Basis of Award for details. | x | |||
| 29 | M.2.6.1.3 | L.1.8.3 | Line 7 | Referenced projects defined by "obligated or funded value exceeding $60 million total or $20 million in any one year" appears excessively large for a procurement seeking small businesses fitting into the $32.5M size standard for NAICS 541513. | Recommendation: L.1.8.1 and M.2.6.1.1, bullet four be changed to read - "The referenced projects shall each be within the recency period and have an obligated or funded value exceeding $30 million total or $7.6 million in any one year". | |||
| Rationale: In latest NAICS revisions, the Small Business Administration reported the "weighted average firm size" in the 541513 NAICS as $7.6M (see Federal Register, Vol 85, No 220 dtd 13 Nov 2020 at https://www.federalregister.gov/d/2020-24903). | The Government appreciates this comment and will make changes to the criteria. Please see updated Instructions to Offerors and Basis of Award for details. | x | ||||||
| 30 | b | 1.8.1/1.8.3 | Our concern is that the requirement of 2.6.1.1 states: For the referenced projects shall each be within the recency period and have an obligated or funded value exceeding $60 million total or $20 million in any one year. The value requirement of $60M million total or $20M over any one year is too high for small businesses within the required NAICS code size standard. | Recommend lowering the annual/total value to an amount such as $2M/$8M which aligns with other small business GWACs; such as Polaris, OASIS SB, and CIO-SP4. For example, to get the maximum points all of these GWACs are under $8M for the cost of the project as an average across the three GWACs. |
As a large business on CIO-SP4, projects of $31M or more will obtain the maximum points available. The amount of $60M greatly exceeds even those amounts required by a large business project. Therefore requiring projects of $60M is inconsistent with other small business opportunities.
| Another way of determining the minimums for past performance would be to calculate an average across the anticipated Task Orders within the IDIQ. It's unreasonable for a small business to meet this requirement, when they must have one contract or task order that fulfills 62% of the 541513 NAICs code size standard($32.5M). | The Government appreciates this comment and will make changes to the criteria. Please see updated Instructions to Offerors and Basis of Award for details. | x | |||||
| 31 | Section 2.6.1.1, 2.6.1.3 | Section 1.8.1, 1.8.3 | In multiple instances in the Proposal Instructions and Basis of Award sections (reference Solicitation Instructions paragraph 1.8.1, 1.8.3, Basis of Award section 2.6.1.1, 2.6.1.3) it is stated “The referenced projects shall each be within the recency period and have an obligated or funded value exceeding $60 million total or $20 million in any one year.” In addition, the references must be a single contract/subcontract or single Task Order (versus a collection of Task Orders, for instance under an IDIQ type contract). The $20 Million in any one year and over $60M total requirement on a single contract or task order appears excessive for a Small Business. The size standard for the NAICS code itself requires the Small Business to have average annual receipts under $32.5M for all contracts/task orders they are performing. As such, the requirement to have references on a single contract/Task Order of at least $20M a year would suggest that a Small Business would have a single contract/task order that represents more than two thirds of their total volume of business. This seems unreasonable and not typical of a Small Business contractor’s portfolio, which would typically be composed of a number of smaller tasks/contracts. The only class of Small Business that this might be achievable for and promote significant competition among is those “Small Businesses” that form a Joint Venture with a large business Mentor under a Mentor-Protégé Joint Venture sort of arrangement. This would significantly limit the ability of standalone, traditional Small Businesses to meaningfully compete for this effort (versus Joint Ventures that can draw on the experience of their Large Business Mentor). | In order to maximize and encourage participation of Small Business recommend specifying a more realistic required Task order/Single Contract value. We suggest at least $2M/year, or at least $10M total. This would ensure that potential small businesses have a significant base of experience in relevant areas to minimize performance risk, while also allowing for an adequate base of competition among Small Businesses for this effort. In addition, in order to ensure traditional standalone small businesses can effectively compete for this effort, versus allowing JV offerors to rely solely on the experience base of their large business Mentor, recommend that offerors that bid as a JV be required to include at least one experience reference from the Protégé member of the JV. | The Government appreciates this comment and will make changes to the criteria. Please see updated Instructions to Offerors and Basis of Award for details. | x | |
| 32 | 2.6.1.3. Support Area 3: Multiple Award ID/IQ Contract for DoD IT Services | 1.8.3 Support Area 3: Multiple Award ID/IQ Contract for DoD IT Services | Would the Government consider revising the project dollar threshold to $30 million total or $10 million in any one year? | The Government appreciates this comment and will make changes to the criteria. Please see updated Instructions to Offerors and Basis of Award for details. | x | ||
| 33 | 2.6.1.1 /2.6.1.3 | 1.8.1/1.8.3 | The requirement of 2.6.1.1 states: For the referenced projects shall each be within the recency period and have an obligated or funded value exceeding $60 million total or $20 million in any one year. The value requirement of $60M million total or $20M over any one year is too high for small businesses within the required NAICS code size standard. It's unreasonable for a small business to meet this requirement, when they must have one contract or task order that fulfills 62% of the 541513 NAICs code size standard($32.5M). | We recommend lowering the annual/total value to an amount such as $2M/$8M which would align with other small business GWACs; such as Polaris, OASIS SB, and CIO-SP4. For example, to get the maximum points all of these GWACs are under $8M for the cost of the project as an average across the three GWACs. As a large business on CIO-SP4, projects of $31M or more will obtain the maximum points available. The amount of $60M greatly exceeds even those amounts required by a large business project. Therefore requiring projects of $60M is inconsistent with other small business opportunities. |
| Another way to determine minimums for past performance would be to calculate an average across the anticipated Task Orders within the IDIQ. Again, It's unreasonable for a small business to meet this requirement, when they must have one contract or task order that fulfills 62% of the 541513 NAICs code size standard($32.5M). | The Government appreciates this comment and will make changes to the criteria. Please see updated Instructions to Offerors and Basis of Award for details. | x | ||||||
| 34 | Attachment 8, Vol II- Support Qualifications, Support area 3 | Can the Government reduce the total obligated dollar value from 60 M to 5M as it is a small business set aside? | Please reduce the total obligated dollar value from 60M to 5M | The Government appreciates this comment and will make changes to the criteria. Please see updated Instructions to Offerors and Basis of Award for details. | x | |||
| 35 | b | 1.8.1/1.8.3 | The requirement of 2.6.1.1 states: For the referenced projects shall each be within the recency period and have an obligated or funded value exceeding $60 million total or $20 million in any one year. Theese values are too high for small businesses within the required NAICS code size standard. | The Government appreciates this comment and will make changes to the criteria. Please see updated Instructions to Offerors and Basis of Award for details. | x | |||
| 36 | 1.7.3 | Unclear if all subcontractors, including those not providing past performance are required to be identified and provide components as outlined in the section | Please clarify this requirement. | The Government appreciates this comment and will updated the Proposal Instructions. | x | |||
| 37 | Section 1.7.3, Page 8, first bullet | Proposal instructions, page 8 first bullet: indicates with respect to the Subcontractor Letter of Commitment that “the intended use of such letters is to support Government validation of any subcontractor qualifications an offeror identifies in response to this solicitation”. It includes, among other requirements, a requirement to provide “a statement of commitment by the proposed subcontractor to support the offeror in performance of GSP Task Orders”. Question: the requirements do not ask the offeror to identify in which general areas of performance the subcontractor is intended to perform. It only requires the subcontractor to provide a statement of commitment to support the offeror in performance of task orders. It also doesn’t ask for subcontractor qualifications related to the areas of performance intended. As such, it is not clear how this can be used to validate subcontractor qualifications an offeror identifies in the proposal. Should the letter identify the intended areas of support and the offerors capabilities in those areas to allow for that validation? | The Government appreciates this comment and will updated the Proposal Instructions. | x | ||||
| 38 | Attachment 8, Volume I, II, III, IV & V | Can we use the subcontractor's experience for each of these volumes? | Please allow subcontractor's experience | The Government appreciates this comment and will make changes to the criteria. Please see updated Instructions to Offerors and Basis of Award for details. | ||||
| 39 | Attachment 8, Vol II- Support Qualifications, Support area 2 | Can we use the subcontractor's evidence for the Supplier Performance Risk System? | Please allow subcontractor's experience | The Government appreciates this comment, however does not anticipate changes to this criteria. | ||||
| 40 | 1.6 | Recency. Due to delays with the Continuing Resolution and the COVID-19 pandemic, will the Government evaluate past performance for this solicitation to be within five (5) years instead of three (3) years? | The SBA extended 8(a) participation by 2 years due to circumstances caused by the pandemic. | The Government appreciates this comment, however does not anticipate changes to this criteria. | ||||
| 41 | 1.8.1 | IT services w/ subcontracted services performed in no less than 4 GSP scope areas | GSP scope has no relationship to qualifying a Prime who has managed multiple subcontractors. Recommend removing the requirement. | The Government appreciates this comment and will make changes to the criteria. Please see updated Instructions to Offerors and Basis of Award for details. | ||||
| 42 | 1.6 | "Recent" is currently defined as three (3) years. Offerors may have relevant project experience that extends back more than three years. | Change "Recent" definition to "five (5) years prior to the closing date of the solicitation." | The Government appreciates this comment, however does not anticipate changes to this criteria. | ||||
| 43 | 2.6.2 | Attachment+8.DRAFT+GSP+TECH+QUAL+WRKSH+13JUL2022 | For Volumes II - V, there are several edits and adds to the project criteria to increase evaluation efficiency and accuracy, to improve clarity of bidder responses and to support the Government's intent to select qualified offerors. These edits and adds are noted in Recommendation column | Recommend: adjust the referenced project count for Scope Areas to One (1) which is consistent with the approach for Areas 1,2,5. The rationale is mainly evaluation efficiency via lower projects. | The Government appreciates this comment and will make changes to the criteria. Please see updated Instructions to Offerors and Basis of Award for details. | |||
| 44 | 2.6.1 | Attachment+8.DRAFT+GSP+TECH+QUAL+WRKSH+13JUL2023 | For Volumes II - V, there are several edits and adds to the project criteria to increase evaluation efficiency and accuracy, to improve clarity of bidder responses and to support the Government's intent to select qualified offerors. These edits and adds are noted in Recommendation column | Recommend: For sub management, recommend One (1) project with Two (2) subs and delete other requirement for Two (2) projects. Rationale is greater relevance in managing Two subs given governance, service delivery, resource, billing and communications issues | The Government appreciates this comment, however does not anticipate changes to this criteria. | |||
| 45 | 2.6.3 | Attachment+8.DRAFT+GSP+TECH+QUAL+WRKSH+13JUL2024 | For Volumes II - V, there are several edits and adds to the project criteria to increase evaluation efficiency and accuracy, to improve clarity of bidder responses and to support the Government's intent to select qualified offerors. These edits and adds are noted in Recommendation column | Recommend: For volume 4, add a criteria for each GEO Area for size of projects to be at least $4.0M per year in size. The rationale is that the existing evaluation approach lacks an emphasis on scale and ability to support greater users within each GEO region. For example, capacity to serve Large, Medium and Small sites. | The Government appreciates this comment, however does not anticipate changes to this criteria. | |||
| 46 | 2.6.2 - 2.6.4 | Attachment+8.DRAFT+GSP+TECH+QUAL+WRKSH+13JUL2025 | For Volumes II - V, there are several edits and adds to the project criteria to increase evaluation efficiency and accuracy, to improve clarity of bidder responses and to support the Government's intent to select qualified offerors. These edits and adds are noted in Recommendation column | Recommend: For VOLS III, IV, and V, set a limit on the total projects that can be referenced to seven (7) per volume. This will permit bidders to substantiate multiple scope areas and set a cap on the number of projects for all bidders. The rationale is greater fairness and reduced administrative burdens on all parties. | The Government appreciates this comment, however does not anticipate changes to this criteria. | |||
| 47 | 2.6.3 | Section 2.6.3.1 states that to be evaluated positively past performances must be for: |
- Services were performed in one (1) or more of the following countries: Germany, Spain, Italy, United Kingdom, Turkey, Japan (including Okinawa Islands), or Korea.
However, this evaluation approach exposes the government to two potential risks. First, if vendors only provide evidence of successful performance in just one of the listed countries, the government will not be able to properly evaluate their ability to support tasks/contracts that cross multiple countries, which more accurately reflect the realities of OCONUS Service delivery. Second, vendors are not required to provide evidence of their success in supporting tasks/contracts in both primary OCONUS regions (Europe and Asia-Pacific), which exposes the government to potential risk because there different legal frameworks and salary norms across different countries/blocks. Recommendation: Revise criteria to require evidence that Services have been performed in both Europe and Asia-Pacific regions. The updated factor would be split into two line items that would require:
- Services were performed in at least two (2) countries, at least one of which must be in the following countries: Germany, Spain, Italy, United Kingdom, or Turkey.
| - Services were performed in at least two (2) countries, at least one of which must be in the following countries: Japan (including Okinawa Islands) or Korea. | The Government appreciates this comment, however does not anticipate changes to this criteria. | |||||||
| 48 | Attachment 8, Vol II- Support Qualifications, Support area 1: | Can the Government change the number of subcontractors from two to one subcontractor? | Please change the number of subcontractors from two to one subcontractor | The Government appreciates this comment, however does not anticipate changes to this criteria. | ||||
| 49 | Addendum 52.212-2 | Addendum 52.212-1 | Volume II Support Qualifications including Support Areas 1, 2, 3, and 4 | As stated in the requirements currently, evidence for all support areas can be provided by the Prime, a JV, or all members of the JV. Unlike in Volumes IV and V, evidence from Subcontractors is excluded. Therefore, a Small Business Prime must bear the entire burden of evidence for all 4 support areas in volume II. However JVs will be evaluated on evidence provided from multiple companies thus putting JVs in an advantaged position. To fix this inequity in the procurement process, we ask that the government please change the requirments to allow for the use of Subcontractor evidence in all 4 support areas and for both of the up to two referenced projects required. | As this is stated to be a Small Business set-aside, the government must give Small Businesses an equal chance of competing as Joint Ventures. Large Businesses have entered into Joint Ventures to allow them to compete as prime contracotrs on small business set-asides, such as this procurement. If the government allows JVs to compete, then Small Businesses must have equal opportunity to draw from evidence sourced across the team. If the government leaves the requirements the same, then there is a risk that experience and knowledge will be lost as large businesses pull all the IT resources out of the MTFs and OLBs, and leave all support services to be provided by low cost centers in remote locations. This will impact responsiveness and quality of IT service delivery. Further, knowledge of legacy systems, investments, and local challenges will be lost. | The Government appreciates this comment and will make changes to the criteria. Please see updated Instructions to Offerors and Basis of Award for details. | ||
| 50 | Addendum 52.212-2 | Addendum 52.212-1 | Volume III Scope Area Qualifications including Support Areas 1, 2, 5, 3, 6, 7, and 4 | As stated in the requirements currently, evidence for all support areas can be provided by the Prime, a JV, or all members of the JV. Unlike in Volumes IV and V, evidence from Subcontractors is excluded. Therefore, a Small Business Prime must bear the entire burden of evidence for all 7 support areas in volume III. However JVs will be evaluated on evidence provided from multiple companies thus putting JVs in an advantaged position. To correct this inequity in the procurement process, we ask that the government please change the requirments to allow for the use of Subcontractor evidence in all 4 support areas and for all 3 of the up to 3 referenced projects required. | As this is stated to be a Small Business set-aside, the government must give Small Businesses an equal chance of competing as Joint Ventures. Large Businesses have entered into Joint Ventures to allow them to compete as prime contracotrs on small business set-asides, such as this procurement. If the government allows JVs to compete, then Small Businesses must have equal opportunity to draw from evidence sourced across the team. If the government leaves the requirements the same, then there is a risk that experience and knowledge will be lost as large businesses pull all the IT resources out of the MTFs and OLBs, and leave all support services to be provided by low cost centers in remote locations. This will impact responsiveness and quality of IT service delivery. Further, knowledge of legacy systems, investments, and local challenges will be lost. | The Government appreciates this comment and will make changes to the criteria. Please see updated Instructions to Offerors and Basis of Award for details. | ||
| 51 | 1.8.3 | Support Area 3: Multiple Award ID/IQ Contract for DoD IT Services. Would the Government consider removing the DoD requirement from this section and allow evaluation of any project for a Federal Agency? | Consistency. The other areas within Attachment 8 are not restricted to DoD awards. | The Government appreciates this comment, however does not anticipate changes to this requirement. | ||||
| 52 | Addendum 52.212-2 paragraph 2.6.1.3 | Addendum 52.212-1 paragraph 1.8.3 | Volume II Support Qualifications Support Area 3 | The requirement for a Multiple Award ID/IQ contract holder to have won at least one competitively awarded | ||||
| order for any DoD IT Services eliminates the use of evidence from awards that were 1. not procured on a MA IDIQ, and 2. that were not awarded competitively. Our question is why are these requirements in the Draft RFP? We respectfully request the government to remove these requirements. | As this is a Small Business set-aside, the government wants to ensure Small Businesses are qualified to do the work and provide resources across the geographic service areas. Work that is relevant and recent should be considered for evaluation purposes regardless of how it was procured or awarded. Satisfactory completion of relevant and recent work for the Federal government should confirm a bidder is qualified. By excluding the use of Direct Award based evidence, and by excluding single award based evidence, the government is disadvantaging Small Business bidders that have delivered high quality services in Military Health and at OLBs. Furthermore, during the last 3 years (recency), during the pandemic, the government awarded a higher proportion of relevant work using direct awards. The government risks the loss of experience and knowledge of staff that have supported the military health community for years at these locations by excluding evidence of from direct awards or from awards that were not part of a multiple award IDIQ contract. | The Government appreciates this comment, however does not anticipate changes to this requirement. | ||||||
| 53 | M.2.6.1.3 | L.1.8.3 | Line 7 | L.1.8.3 and M.2.6.1.3, Second Bullet, restricts offerors by being a “Multiple Award ID/IQ contract holder having won at least one competitively awarded order for any DoD IT Services.” | Recommendation: Change title of L.1.8.3 and M.2.6.1.3 to read - “Support Area 3: Single or Multiple Award ID/IQ Contract for DoD IT Services” and change second bullet in L.1.8.3 and M.2.6.1.3 to read – “Single or Multiple Award ID/IQ contract holder having successfully been awarded Task or Deliver Orders for any DoD IT Services.” Rationale: Single Award ID/IQs still require the awardee to bid, price and fairly negotiate with the Government to receive award of Delivery Order RFPs through the life of the contract and award is not guaranteed. | The Government appreciates this comment, however does not anticipate changes to this requirement. | ||
| 54 | Addendum 52.212-2 paragraph 2.6.1.3 | Addendum 52.212-1 paragraph 1.8.3 | Volume II Support Qualifications Support Area 3 | The current selection criteria Gerrymanders the Small Business community in such a way it eliminates the participation of a very large number of small businesses that are fully capable of doing the work. This is not in the spirit of long term competition nor in the best pricing interest of the Government especially, for a 10 year contract. We would ask that you please remove the “Competitively Won” and IDIQ Requirement. | If the government granted a Direct Award to a company to perform a contract the government must have previously determined that the contractor was qualified to perform the work and in many cases is still performing the work. If you keep this requirement you would be eliminating small business contractors that the government has previously determined have the capability to perform the work. If the Government would like to ensure that the company can perform the work then the best option would be to use a past performance questionnaire method to determine the performance. Since this requirement primarily effects small business 8a contractors with “Non-Competitively Won” awards and SBIR Direct Awards, it does not promote a spirit of competition amongst clearly capable small businesses that have been doing this type of work for years. The current selection criteria Gerrymanders the Small Business community in such a way it penalizes a very large number of small businesses that are fully capable of doing the work. I recommend removing both the “IDIQ” and “Competitively Won” requirements in this section to avoid pre-RFP protest of this solicitation. | The Government appreciates this comment, however does not anticipate changes to this requirement. | ||
| 55 | Addendum 52.212-2 paragraph 2.6.1.3 | Addendum 52.212-1 paragraph 1.8.3 | Volume II Support Qualifications Support Area 3 | Over the past few years due to the pandemic the government has elected to take advantage of direct awards as a quick easy acquisition solution for a number of Urgent request. Since this type of award benefits the government as well as the 8a contractors why would you discriminate against the contractors for receiving a direct award from the government? We would ask that you please remove the “Competitively Won” and IDIQ Requirement. | If the government granted a Direct Award to a company to perform a contract the government must have previously determined that the contractor was qualified to perform the work and in many cases is still performing the work. If you keep this requirement you would be eliminating small business contractors that the government has previously determined have the capability to perform the work. If the Government would like to ensure that the company can perform the work then the best option would be to use a past performance questionnaire method to determine the performance. Since this requirement primarily effects small business 8a contractors with “Non-Competitively Won” awards and SBIR Direct Awards, it does not promote a spirit of competition amongst clearly capable small businesses that have been doing this type of work for years. The current selection criteria Gerrymanders the Small Business community in such a way it penalizes a very large number of small businesses that are fully capable of doing the work. I recommend removing both the “IDIQ” and “Competitively Won” requirements in this section to avoid pre-RFP protest of this solicitation. | The Government appreciates this comment, however does not anticipate changes to this requirement. | ||
| 56 | 1.8.4 | Facility Clearance | Change to state the business must be able to support a facility clearance which will be sponsored by the Government for this award. | The Government appreciates this suggestion, however does not anticipate changes to this criteria. | ||||
| 57 | 1.8.3 | Support Area 3: Multiple Award ID/IQ Contract for DoD IT Services. Would the Government consider allowing subcontractor awards to be evaluated as well? | Consistency and Robust Competition. The Government allows for subcontractor awards in other areas of Attachment 8. By restricting Support Area 3 to DoD awards held by the prime with a value of $60 million total or $20 million in any one year, the Government is severely limiting small business competition. | The Government appreciates this comment and will make changes to the criteria. Please see updated Instructions to Offerors and Basis of Award for details. | ||||
| 58 | 2.6.2.1 | Why the requirement to have a combination of scope areas 1,2, and 5 on a single project? Theoretically a company could have a project with six of the GSP Scope Areas, but if one of the three (1,2,or 5) scope areas was not included, then that project wouldn't be able to be submitted. Moreover, every other task area (3,4,6 and 7) is allowed to have up to 3 projects that cover each of those areas. | Recommend the government either change scope areas 1,2, and 5 to reflect the same requirements as the other scope areas or allow more that one project that could demonstrate performance in the three scope areas. For example, one project may cover scope area 2 and 5 while another covers scope area 1. | The Government appreciates this comment. Please see updates to the criteria. | x | |||
| 59 | 2.6.2.1 | What is the government's intent with the requirement to have a combination of scope areas 1,2, and 5 on ONE project? For example, a company could have a project with six of the GSP Scope Areas, but if one of the three (1, 2,or 5) scope areas was not included, then that project wouldn't be able to be submitted. Additionally, every other task area (3,4,6 and 7) is allowed to have up to 3 projects that cover each of those areas. | We recommend that the government either change scope areas 1,2, and 5 to reflect the same requirements as the other scope areas or allow more that one project that could demonstrate performance in the three scope areas. | The Government appreciates this comment. Please see updates to the criteria. | x | |||
| 60 | 2.6.2.1 | Why is htere a the requirement to have a combination of scope areas 1,2, and 5 on a single project? A company could have a project with six of the GSP Scope Areas identified, but if one of the three scope areas 1, 2, or 5 is not included, that project wouldn't be able to be submitted. As written, every other task area (3,4,6 and 7) will be allowed to have up to 3 projects that cover each of those areas. | Recommend the government either change scope areas 1,2, and 5 to reflect the same requirements as the other scope areas. This allows more that one project that could demonstrate performance in the respective three scope areas. A project may cover scope area 2 and 5 while another covers scope area 1. | The Government appreciates this comment. Please see updates to the criteria. | x | |||
| 61 | 1.9 Volume III Scope Area Qualifications | Given that many of the PWS task areas and requirements are not included within Section 1.9.1 of the Proposal Instructions, can the Government please confirm that the Government intends to evaluate offerors based on their ability to meet the Scope requirements as listed within 1.9.1 only, and not based upon their ability to demonstrate evidence for all requirements within the PWS? | The Government intends to evaluate Offerors based on the qualifications listed within the Proposal Instructions and Basis of Award. | |||||
| 62 | Addendum 52.212-2 | Addendum 52.212-1 | Support Qualifications | Please include in the instruction for past performance that the Government will allow Affiliated Past Performance as part of the prime contractor experience. | Many companies are structured with multiple divisions or multiple legal entities that individually perform Prime Contracts, but fall under a broader corporate umbrella. Recognizing such corporate structures exist across the industry, the procurement rules and numerous GAO decisions have made clear that procuring agencies may evaluate and credit an offeror with the past performance and corporate experience of affiliate companies where the offeror’s proposal demonstrates that the resources of the affiliate (e.g., workforce, management, facilities, or other resources) will be meaningfully contributed to contract performance. See GM–Bulltrack, B- 414591.6 (Comp. Gen. Oct. 30, 2018)(holding that an agency may properly attribute the experience or past performance of an affiliated company), and Iyabak Construction, LLC, B-409196 (Comp. Gen. Feb.6, 2014)(holding that the agency failed to articulate a rational basis for solicitation’s refusal to consider experience and past performance of affiliates). | The Government is asking for experience from specific entities under Support Area Qualifications, as stated, and affiliates are not an acceptable entity for these qualifications. |
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