DRAFT RFP HT001526RE001QA Government Responses FINAL 0260422.xlsx
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- Solicitation number
- HT001526RE001QA
- Issued by
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Defense Health Agency
About this file
This is a Government Q&A Response document addressing industry questions and feedback on Draft RFP HT001526RE001 for Clinical Reference Laboratory Testing Services, issued by the Defense Health Agency on February 20, 2026. The document contains 36 numbered questions with corresponding government responses regarding solicitation requirements, evaluation criteria, and technical specifications.
Key clarifications provided include: formatting requirements standardized to 11-point minimum font (Times New Roman or Arial) with tables at 8-point minimum; evaluation will use a best-value tradeoff approach emphasizing past performance as the primary differentiator between acceptable technical proposals and pricing; small business participation goals of 30% total, 5% SDB, 5% WOSB, 3% HUBZone, and 3% SDVOSB remain unchanged with good faith effort documentation required if goals cannot be met; New York State Department of Health licensing requirements apply only where applicable; estimated contract quantities for CLINs 0002-0003 and 1002-1003 have been revised to reflect five-year base and option period estimates with no volume guarantees; STAT courier pickup requirements of three hours apply to all locations including OCONUS; contract includes a Technology and Pricing Refresh mechanism and On-Demand Technology Integration provisions to ensure incorporation of emerging diagnostic technologies; CMMC Level 2 certification is required at contract award as a condition of performance; HL7 V2.3 messaging standards will govern MHS Genesis interface with one bi-directional interface supporting the entire enterprise; subcontracted CLIA-certified specialty laboratories are acceptable provided they meet regulatory, accreditation, and security requirements; and NIST SP 800-171 and CMMC requirements apply to PHI/PII handling under this contract.
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Q&A
DRAFT - RFP HT001526RE001
Issued 20 Feb 2026
| Question # | PWS Reference, Attachment or Exhibit | Concern/Question/Comment | Vendor Recommendation/Rationale | Government Response |
| 1 | Attachment 2, Sec/Para. A.3.d General Formatting | RFP states, "A minimum of 11-point font size . . .", and also "Tables and illustrations may use a reduced font size of not lett than 8-point . . .". Later in same paragraph you state, "12-point font. Tables and exhibits may use a minimum 10-point font." | Please rewite to read "All narrative text must not be less than 12-point Times New Roman or Arial font size and type. Text within tables and illustrations must use Times New Roman or Arial font type, with a minimum font size of 9-points." | Concur: Attachment 2, - Addendum to Far 52.212-1, paragraph A.3.d. has been revised as "General Formatting. A minimum of 11-point Times New Roman or Arial font size applies throughout all volumes. Margins: Standard 1" around the page (top, bottom. left and right sides), Width - 8.5 inches, Height - 11 inches with margins of at least one (1) inch on all sides. Tables and illustrations may use a reduced font size not less than 8-point and may be landscape. |
| 2 | Attachment 2, Sec. C. Basis of Award, 1st Paragraph; |
Sub-bullet 2 & Attachment 3, Sec. B. Basis for Award
Attachment 3, Sec. M Solicitation states, "best-value tradeoff process . . .", with its ". . . Non-price factor (Past Performance)" being the only evaluation factor in which best-value trade-off analysis can be performed on.
Factor 2 (Past Performance) is the only non-price factor that allows for any differentiation in a Best-Value evaluation.
As the RFP is currently written there is a structural issue in Section M affecting the Government’s ability to conduct a true ”best value tradeoff” as intended. Although Factor 1 (Technical) is identified as the most important evaluation factor, it is currently evaluated only on an Acceptable/Unacceptable basis. When the highest weighted factor is binary—and Past Performance is assessed using a normalized confidence rating—the evaluation effectively becomes Lowest Priced Technically Acceptable (LPTA). Under this structure, meaningful differentiation in technical quality, innovation, or approach risk cannot influence the award decision, and price becomes the de facto primary discriminator.
To preserve the intended best value tradeoff, Section M should be revised to allow:
• Adjectival ratings with integrated risk assessment for Factor 1 (Technical)
• Adjectival confidence ratings for Factor 2 (Past and Present Performance)
• A clear statement that Factors 1 and 2 together carry significantly more weight than price
• A tradeoff methodology allowing the Government to select higher technical merit even at a higher price when justified by value or reduced risk Non-Concur: The Government has determined the requirements for Factor 1 (Technical) are well-defined and can be objectively evaluated on an Acceptable/Unacceptable basis. The Government does not anticipate receiving additional value or innovation for this factor that would warrant paying a price premium.
Therefore, this procurement is structured to emphasize past performance as the primary differentiator for the best-value tradeoff decision. The tradeoff analysis, as intended and described in Attachment 3, will occur between Factor 2 (Past and Present Performance) and Factor 4 (Price). This allows the Government to assess its confidence in an offeror's ability to successfully perform the work and to determine whether a higher confidence rating in past performance justifies a higher price.
The evaluation criteria as stated in the solicitation are consistent with FAR Part 15 and provide the flexibility for the Government to conduct the intended best-value tradeoff.
| 3 | N/A | To support budget stability and simplified administration, would the DoD consider inclusion of a standardized monthly pricing structure as an allowable pricing methodology within the RFP? | N/A | Non-concur: The Government is satisfied with the pricing structure as written. |
| 4 | Attachment 3, Sec. H. Volum V - Factor 4: Small Business Subcontracting Participation Proposal | Subsection 1 states the small business goals rather than the minimum requirements. | The clinical laboratory testing industry is subject to significant government regulation at the federal, state, and local levels. The technical equipment and supplies it requires are subject to stringent regulatory requirements. These regulatory compliance standards limits the labooratory's ability to procure such services and supplies from many small businesses. As such, we propose rewriting the Sec. H and Subsection 1 as follows - |
The offeror’s Small Business Participation Commitment Document will be evaluated on an “Acceptable” or “Unacceptable” basis. The Small Business Participation Commitment Document must demonstrate a comprehensive, realistic, and sound commitment to meeting the Government's socioeconomic objectives for this acquisition. To be rated Acceptable, the Small Business Participation Commitment Document must meet the minimum requirement outlined below. A proposal that fails to meet the minimum requirement will be rated Unacceptable and will be ineligible for award.
1. Standard for Quantitative Participation (Acceptable/Unacceptable)
To be rated Acceptable, the offeror’s proposal must meet or exceed the minimum requirement listed below.
The minimum requirement for Total Small Business participation is 3%.
The Government’s small business goals for this acquisition are:
a. Total Small Business: 30%
b. Small Disadvantaged Business (SDB): 5%.
c. Woman-Owned Small Business (WOSB): 5%
d. HUBZone Small Business: 3%
e. Service-Disabled Veteran-Owned Small Business (SDVOSB): 3%
A document that fails to meet the minimum requirement above will be rated Unacceptable. REVISED RESPONSE - Not Concur: The Government does not concur with replacing "small business goals/objectives" with "minimum requirements". While the Government's intent is to maximize small business participation for this requirement, we realize that offerors may find it challenging or not feasible to meet these goals. As such, if the offeror cannot meet one or more of these goals, they must provide a detailed explanation and verifiable documentation demonstrating a Good Faith Effort to maximize small business utilization.
Additionally, the Government does not concur with the recommendation to lower the minimum goal for Total Small Business participation to 3%. The minimum goal remains 30% as stated in Attachment 2, Addendum to FAR 52.212-1, Paragraph H.1.a.(3), Volume IV - Factor 3: Small Business Subcontracting Participation Proposal.
5 Attachment 3, Sec. E Subsection 3 Subfactor 1A Technical Approach Clarification for New York Department of Health licenses requirement New York State Department of Health licenses are required when laboratories accept or perform testing on specimens originating from New York State.
Please rewrite Laboratory Testing Evaluation Criteria to read -
To be Acceptable: The proposal provides documentation certifying that all proposed prime and subcontractor laboratories are licensed to perform testing on human specimens in accordance with the Clinical Laboratory Improvement Amendments (CLIA) of 1988 and possess, where applicable, New York State Department of Health licenses. Unacceptable: The proposal fails to provide the required certifications.
| Concur: Attachment 2, Paragraph F, subparagraph 6b, Attachment 3, Paragraph E subparagraph 3, Subfactor 1A Technical Approach, and PWS paragraph 5.2.1. have all been revised. | |
| 6 | Attachment 1 - DRAFT - Performance Work Statement #6.3.1 |
#6.3.1.1
| #6.3.1.1.2 | 6.3.1 (6.3.1 - 6.3.1.1.2) Is the requirement for Contractor Information Assurance staff to be located at a DoD facility? Or for Contractor Information Assurance staff generally? | Clear distinction will promote consistent proposal assumptions. | Clarification: PWS paragraph 6.3.1. and subparagraphs 6.3.1.1. and 6.3.1.1.2 are applicable to all contractors (regardless of location) that access the DHA Network, DoW Network, or MHS Genesis. |
| 7 | Exhibit A - DRAFT Price List Schedule of Required Tests | We recommend including the following for each test: |
Current provider test code, Current performing vendor name,
| CPT code | In order for all Offerors to provide an accurate and equitable test comparison, and accurately price the provided test list. To Reduce the odds of incorrect test mapping. | Concur: See updated Exhibit A - Price List - Schedule of Required Tests, Column A - Current Lab Test Name, Column E - CPT Code, and Column G - Prime Vendor or Subcontract Performed. The Government does not concur with adding "current provider test code" or the "current performing vendor name". | |||
| 8 | Exhibit A - DRAFT Price List Schedule of Required Tests | We recommend adding a column(s) to provide space for Offerors to include their specific Test Code, Service Code, and Test Description within the pricing attachment. | To improve the accuracy of proposals and prevent potential discrepancies. | Concur: See updated Exhibit A Price List - Schedule of Required Tests that includes additional columns: C - Test Methodology, D - FDA or LDT, F -Turnaround Time, and G- Prime vendor or subcontractor performed. Additonal pertinent information may be enterred in Column L - Comments for the correlating test. | |
| 9 | PWS Sections 1.13 (Contractor Travel) and 1.14 (Other Direct Costs) | Reserved Sections: PWS Sections are marked as "RESERVED". | These sections are essential for pricing non-routine requirements, such as medico-legal testimony, which the PWS notes is not included in the fixed price. | REVISED RESPONSE - Partially Concur: The reference to PWS 1.13 and 1.14 was incorrect; the relevant paragraphs are 1.8 and 1.9, which are reserved. |
However, the Government acknowledges that PWS paragraph 5.3.2.2 identifies medico-legal testimony as an Other Direct Cost (ODC) not to be included in the fixed-price. To address this, the Government will either add an ODC CLIN to the contract for these services or handle such requirements via separate contract modification on an as-needed basis. Offerors shall not include costs for medico-legal testimony in their fixed-price unit costs in Exhibit A, Schedule of Required Tests.
| 10 | Exhibit A - DRAFT Price List Schedule of Required Tests and SF1449 | There is a significant lack of clarity regarding projected volumes. Exhibit A (Price List) identifies a total estimated yearly quantity of 1,799,616 units, whereas the Solicitation Supplies or Services section for CLIN 0002 lists 500,000,000 units. | This discrepancy must be resolved to allow for accurate pricing | REVISED RESPONSE - CONCUR: The estimated quantities provided for CLINs 0002, 0003, 1002, and 1003 have been revised and now reflect the estimated five-year quantities for the base and option periods. These figures do not represent a guaranteed volume of work. Offerors must propose their own fully-burdened, fixed-price unit rates in Exhibit A, which will be multiplied by the quantities to calculate the total evaluated price for these CLINs. | |
| 11 | PWS 5.3.5.2 "Unscheduled/STAT" Courier Requirements | The requirement is for pickup "within 3 hours after notification." For remote or OCONUS sites (e.g., Landstuhl,Germany), a 3-hour physical pickup window by a courier may be logistically impossible or prohibitively expensive if the contractor does not have a local hub. | Recommendation: Clarify if this 3-hour window applies to all locations globally or only | ||
| CONUS locations near major metropolitan hubs or consider expanding this requirement. | Concur: PWS paragraph 5.3.5.2. is applicable to all DoW and DHA sites to include OCONUS and CONUS locations. Paragraph language has been revised for clarification. | ||||
| 12 | FAR 52.212-1 Addendum | The instructions provide a clear structure for the five required volumes and the "Demonstrate, Don't Restate" principle. However, there is a conflict in formatting requirements: Font Size Inconsistency: Paragraph (d) states that a "minimum of 11-point font" applies throughout yet later specifies that "All pages shall be in Times New Roman or Arial, 12-point font". This inconsistency could lead to inadvertent non-compliance. | Requesting Clarity | Concur: See Response #1 | |
| 13 | Sub-factor 1A | New York State Licensing: Sub-factor 1A mandates that all proposed prime and subcontractor laboratories possess New York State Department of Health licenses. Because many regional labs do not maintain this license if they do not process New York specimens, this requirement may inadvertently limit competition. | appear[s] overly restrictive or lack sufficient detail to ensure a level playing | ||
| field | REVISED RESPONSE - CONCUR: As stated in the response to Question #5, the requirement for New York State Department of Health licenses has been clarified to apply "where applicable". This change is reflected in Attachment 2, Section F.6.c. | ||||
| 14 | PWS 1.6 | Processor Scheduling: PWS 1.6 allows the contractor to determine a "staffing formula" for on-site specimen processors. This is ambiguous and may lead to inconsistent service levels across the 16 MTFs. Providing minimum hours of on-site coverage would ensure uniform service. Is the government asking for a specific number of Full-Time Equivalents (FTEs) based on volume, or just a methodology? Without a baseline workload estimate, offerors may drastically over- or under-bid the labor required. | Recommendation: Provide historical data on the average number of processors currently |
utilized at these 16 sites or provide a "workload per FTE" standard to ensure fair
| competition. | Concur: The Government has amended the PWS. A column has been added to the chart at PWS paragraph 1.5.3. providing the average monthly test volume handled by the incumbent. This historical data is provided for informational purposes only and to assist offerors in preparing their proposals. It does not represent a guarantee of future test volumes. Each offeror is solely responsible for developing a comprehensive staffing methodology and approach to meet the performance requirement of ensuring all specimens are processed and sent out in accordance with the PWS, regardless of fluctuations in workload. The Government will not dictate or endorse any specific staffing solution. | ||||
| 15 | PWS 5.3.7.2. | Web-Portal Intent: There is ambiguity regarding the web-based system mentioned in PWS 5.3.7.2. It is unclear if this is intended strictly for emergency/contingency use or for daily redundant access alongside the LIS interface. The understanding is that the orders are placed in MHS GENESIS which is integrated with the vendor LIS and direct access | |||
| to the LIS is on an emergency/contingency basis. | Clairification: The web-based system identified in PWS paragraph 5.3.7.2 needs to be available at all times in the event of a contigency that prevents the transmission of data through MHS Genesis/LIS Interface. | ||||
| 16 | PWS 5.3.14 | Specimen Retention: PWS 5.3.14 requires retention for 7 days (up to 30 upon request). Standard commercial retention for serum/blood is often 7-10 days due to storage volume constraints. 30 days is significant. | Recommendation: Ensure the pricing schedule (Exhibit A) allows the contractor to account for the storage costs of the "30-day on request" requirement, or make "Extended Storage" a separately priced CLIN. | Non-concur: Offerors should consider the timeframe identified in PWS paragraph 5.3.14 and address in their proposal as they deem appropriate. No adjustments of this nature will be made to the Pricing Schedule (Exhibit A) | |
| 17 | Sub Contracting Proposal | Given that large national laboratory contractors possess significantly greater market share and infrastructure compared with regional laboratories, could the Government clarify how it intends to ensure adequate competition and price reasonableness if the requirement is competed on an unrestricted basis? Additionally, given the presence of numerous CLIA-certified high-complexity laboratories that qualify as small businesses and are capable of performing the required testing services, would the Government consider structuring the procurement as a total or partial small-business set-aside in accordance with FAR 19.502-2 (Rule of Two) to promote broader competition and participation by qualified small laboratories? | Non-concur: Market research conducted in advance of this requirement determined that it was unlikely the Government would receive proposals from two or more small businesses that were capable of performing at the scope, scale and geographic coverage required. As such, the Government made the determination to solicit this requirement as a full and open competition. |
The Government will ensure price reasonableness through adequate price competition among offerors and may use other price analysis techniques as described in FAR 15.404-1. The evaluation criteria are designed to ensure a fair and equitable competition for all offerors.
| 18 | PWS - Laboratory Testing Scope | Please clarify whether the Government intends to allow subcontracted CLIA-certified specialty laboratories to perform advanced molecular diagnostics such as next-generation sequencing (NGS), hereditary cancer testing, and pharmacogenomic testing. | Recommend allowing qualified CLIA-certified specialty laboratories to support advanced molecular and genetic diagnostic services as subcontractors to the prime contractor. | Concur: Subcontracted CLIA-certified laboratories are acceptable provided those subcontracted labs meet all required regulatory, accreditation, and security requirements. |
| 19 | PWS - Electronic Data Interface | Will the Government permit integration using industry-standard HL7 interfaces or secure API connections between contractor Laboratory Information Systems and the MHS Genesis electronic health record? | Recommend permitting industry-standard HL7 or API-based integrations to support interoperability and reduce implementation complexity. | Concur: HL7 is the standard messaging interface. |
| 20 | PWS - Specialized Testing | For esoteric or low-volume specialty testing, may the prime contractor utilize qualified reference laboratories as subcontractors? | Recommend allowing subcontracted reference laboratories for esoteric or specialized testing to ensure clinical accuracy and operational efficiency. | Concur: Refer to Response #18. |
| 21 | Evaluation Criteria | Will the Government consider specialized laboratory subcontractors as part of the prime contractor's past performance evaluation? | Recommend allowing subcontractor past performance for specialized molecular diagnostic services to be considered in the technical evaluation. | Concur: Offerors submitting proposals must consider the entirity of this requirement. Prime vendors may elect to choose subcontractors with specialized laboratory experience as a part of their solution and may submit relative past performance in their Performance Risk (Present and Past Performance) volume (Factor 2) for consideration/evaluation. Specialized laboratory experience will not be considered under the Technical (Factor 1) evaluation. |
| 22 | H Volume IV - Factor 3 #4 Attachment 2 - Addendum to FAR 52.212-1 Instructions to Offerors | Can the government clarify how the proposed 10-year structure will not limit continued incorporation of emerging diagnostic technologies, evolving standards of care, and advancements in laboratory science throughout the life of the contract? | Consider a shorter base that will allow for market reassessment and ensure that new and emerging technologies would be accessible via this contract vehicle. | Clarification: The contract incorporates a Technology and Pricing Refresh (TPR) mechanism (see Special Contract Requirements, Part 1) specifically to re-baseline the contract with new technology before the option period. Furthemore, Section (d) of that clause allows for On-Demand Technology Integration at any time during performance via bialteral modification. These clauses are designed to ensure the contract remains current with advancements in laboratory science. |
| 23 | F Volume III - Factor 2 #1.a Attachment 3 - Addendum to FAR 52.212-2 Evaluation Criteria | How does the government intend to normalize the evaluation of past performance and technical experience between the incumbent and non-incumbent offers, particularly where the incumbents experience is directly tied to the performance under the current contract. | Since DHA is unique in size and scope, consider evaluating on functional complexity, not contract size alone. Additionally, consider allowing offeror's to combine multiple contracts to demonstrate comparable scope. Avoids unfairly penalizing responding firms other than the incumbent. | Clarification: The Government will evaluate past performance in accordance with the criteria set forth in the Addendum to FAR 52.212-2, Section F. The evaluation will assess the recency, relevance, and quality of the performance. Relevance is determined by the scope, magnitude, and compexity of the effort compared to this solicitation's requirements, not solely on contract size or incumbency. Offerors are premitted to submit any references they believe best demonstrate their capabilities, and teh Government will evaluate them according to these stated criteria. |
| 24 | Attachment 3 - Addendum to FAR 52.212-2 Evaluation Criteria | Can the government clarify how it intends to mitigate inherent incumbent advantages to ensure a fair and equitable evaluation of non-incumbent offers? | Protect procurement integrity and ensure evaluation is based on the solicitation, not incumbent-only knowledge or artifacts. | Clarification: The Government is required to conduct a fair and impartial evaluation of all proposals received. The evaluation will be based exclusively on the contents of the submitted proposal and its adherence to the requirements of the solicitation, not on any pre-existing or incumbent-specific knowledge or access. |
| 25 | B: Basis of Award #3 Attachment 3 - Addendum to FAR 52.212-2 Evaluation Criteria | Neutral Confidence handling (fairness for new entrants): The draft states Neutral Confidence is eligible and not evaluated favorably or unfavorably. In the best-value tradeoff, how will DHA treat Neutral Confidence when compared to Satisfactory/Substantial Confidence—i.e., is Neutral simply “not a discriminator,” or will it still be viewed as higher performance risk in the tradeoff narrative? | Ensures the Government’s tradeoff doesn’t unintentionally penalize firms without highly-relevant federal past performance, contrary to the stated neutral policy. | Clarification: As stated in the Addendum to FAR 52.212-2, Section F,3, Table 2, a rating of "Neutral Confidence" means the offeror will not be evaluated favorably or unfavorably. In a best-value tradeoff analysis, this factor would not be a positive discriminator for the offeror, but it would also not be viewed as a risk or a negative discriminator. |
| 26 | Attachment 3 - Addendum to FAR 52.212-2 Evaluation Criteria | Specifically, how will the evaluation criteria account for differences in access to staff/leadership, historical performance/needs and operational familiarity? | Protect procurement integrity and ensure evaluation is based on the solicitation, not incumbent-only knowledge or artifacts. | Clarification: See response to question 24. | |
| 27 | Attachment 3 - Addendum to FAR 52.212-2 Evaluation Criteria | Clarify how the small business subcontracting goal requirement aligns with the services provided under this contract, where the awarded work will likely be absorbed into an offeror's existing operational infrastructure and supply chain? | Understanding this distinction will help industry align proposal strategies with the government's intended outcome. | Clarification: The small business subcontracting goals apply to the total contract value. Offerors are expected to seek out and provide maximum practicable opportunities for small business across the full scope of contract performance. This includes not only direct performance of laboratory testing but also indirect support such as logistics, courier services, supplies, information technology services, and administrative support necessary to fulfill the contract's requirements. | |
| 28 | C: Factors and Relative Importance Attachment 3 - Addendum to FAR 52.212-2 Evaluation Criteria | Interface fairness / equal artifacts: Since LIS ↔ MHS GENESIS interfacing is a major technical subfactor, will DHA provide all offerors the same integration artifacts and, if applicable, a standard non-production test approach so evaluation is based on the proposed method and ability—not incumbent-only access and “implicit or legacy knowledge"? | Reduces incumbent advantage and supports apples-to-apples evaluation of Sub-factor 1B: Transition Approach and Laboratory Information System (LIS) Interface | Clarification: The Government intends to be as transparent as possible with regard to the interface process and provides the following information: The lab interface is a bi-directional interface using Transport Layer Security (TLS) 1.2 or 1.3 encryption, Federal Information Processing Standards (FIPS) compliance cypher keys and industry standard HL7 V2.3 Order Message (ORM) and Observation Result - Unsolicited (ORU) message traffic. The Government Program Office requires interface testing with our pre-prod system using test data in advance of establishing new connections to our production system. Consideration will be made to accommodate newer versions of the HL7 standards but will not deviate from a published industry standard communication protocol. HL7 Standards Website accessible to the general internet: https://www.hl7.org/implement/standards/index.cfm?ref=nav | |
| 29 | #5.3.7 Attachment 1 - DRAFT - Performance Work Statement | Will the interface with MHS Genesis utilize a single database? | Providing detailed interface specifications will promote full and open competition by ensuring all offers, including non-incumbents, can prepare comparable implementation plans and pricing strategies. | Clarification: No, the number of databases used by our system is not relevant, external systems will use one bi-directional HL7 V2 interface with MHS GENESIS to support the entire enterprise. | |
| 30 | #5.3.7 Attachment 1 - DRAFT - Performance Work Statement | Will individual interfaces be required with each MTF or do some MTF’s share an interface instance? | |||
| If the MHS Genesis interface is not one instance, is it branch specific? Is it region specific? Is a single test compendium utilized or do different MTF’s customize by site? | Providing detailed interface specifications will promote full and open competition by ensuring all offers, including non-incumbents, can prepare comparable implementation plans and pricing strategies. | Clarification: One bi-directional HL7 V2 interface with MHS GENESIS supports the entire enterprise. | |||
| 31 | E Volume II - Factor 1 #4 Attachment 3 - Addendum to FAR 52.212-2 Evaluation Criteria | Evaluation Criteria states that to be Acceptable: At the time of proposal submission, the Government is able to verify in the Supplier Performance Risk System (SPRS) that the offeror has a current NIST SP 800-171 DHS Assessment (Basic) posted. PWS 6.4.2 states the contractor shall, at time of award, have posted a current basic NIST SP 800-171 self-assessment summary-level score in the Supplier Performance Risk System (SPRS) via the PIEE. | Update RFP to consistently indicate at time of award or at time of go-live. | Clarification: The Government confirms that CMMC compliance is a condition of award, not proposal submission. The reference in the original draft of Attachment 3 was based on a since-rescinded DFARS clause and is superseded by the CMMC requirements detailed elsewhere in the solicitation. Evaluation Criteria states that to be Acceptable: At the time of proposal submission, the Government is able to verify in the Supplier Performance Risk System (SPRS) that the offeror has a current NIST SP 800-171 DHS Assessment (Basic) posted. The solicitation will be amended to ensure consistency. The controlling requirement is that a current CMMC status must be posted in SPRS at the time of contract award. | |
| 32 | N/A PWS Attachment 3 - B2B Gateway Implementation Plan and Questionnaire | Clarify why IP addresses between the firewall and the internet would be needed on the diagram. The data/communication is all encrypted until it reaches the firewall. | Clarifying this requirement will help ensure that proposal submissions align with true needs. | Clarification: Including the IP address on a diagram is not required at this point. After contract award, the Government program office will work with the selected vendor to develop a Ports, Protocols and Services Mangement (PPSM) document to include the IP addresses, ports and protocols used to connect the systems. The PPSM will be reviewed and approved through the Government's configuration management process and will be processed by the firewalls teams. | |
| 33 | #1.5.5 |
#6.1
| #6.11 Attachment 1 - DRAFT - Performance Work Statement | Clarification needed on the following requirements - as it's not clear on which is required, or if the NIST 800 171 self assessment and the CMMC Level 2 self assessment expected to have the same score? | ||
| • | Posting a NIST 800 171 basic assessment score in SPRS (6.4), and | ||
| • | Posting a CMMC Level 2 self assessment score in SPRS (6.11) | ||
| • | Phase-in period to comply with all requirements (1.5.5) | Reduces confusion among vendors, ensures all vendors interpret the same. | Clarification: The CMMC requirement supersedes the previous NIST SP 800-171 DoD Assessment process for contracts with CMMC requirements. The CMMC Level 2 security requirements are identicial to the 110 contorl requirements prescribed in the NIST SP 800-171 Rev 2. Therefore, depending on the CMMC Level specified in the solicitation, a current CMMC status is required at time of contract award. There is only one CMMC status to be posted in the SPRS, which reflects the result of the CMMC Level assessment. For example, if CMMC Level 2 (Self) was prescribed in the solicitation, then the CMMC Level 2 self-assessment results are posted in the SPRS by the Offeror. If CMMC Level 2 (C3PAO) was prescribed in the solicitation, then the C3PAO will post the CMMC status results in e-MASS which is automatically reported into the SPRS. The contractor shall annually affirm their CMMC status in SPRS. |
| 34 | #1.5.5 |
#6.1
| #6.11 Attachment 1 - DRAFT - Performance Work Statement | Is the expectation that two separate entries be posted in SPRS? | ||
| • | Posting a NIST 800 171 basic assessment score in SPRS (6.4), and | ||
| • | Posting a CMMC Level 2 self assessment score in SPRS (6.11) | ||
| • | Phase-in period to comply with all requirements (1.5.5) | Reduces confusion among vendors | Clarification: See response to question #33 |
| 35 | #6.4 Attachment 1 - DRAFT - Performance Work Statement | Clarification for what is required at time of award, as these requirements appear to be conflicting: | |
| • | You must have a completed NIST 800 171 basic self assessment posted in SPRS. | ||
| • | You must have a CMMC Level 2 self assessment posted in SPRS. | ||
| • | You must submit an SSP + POA&M(s) showing your plan to reach full compliance | Reduces confusion among vendors | Clarification: These are not conflicting requirements but are sequential parts of the compliance process. Granted, the solicitation prescribed the requirement for NIST 800-171 basic self-assessment posted in SPRS prior to latest Revolutionary FAR Overhaul (RFO) to DFARS 252.204-7019. However, CMMC requirements supersede NIST SP 800-171 basic self-assessment scoring posted in SPRS. According to 32 CFR Part 170, a contractor can be eligible for award with a "Conditional" CMMC Level 2 status (assuming CMMC Level 2 Self or C3PAO was prescribed in the solicitation). This is achieved if the contractor has an up-to-date System Security Plan (SSP), meets a minimum score on their CMMC assessment, and has a Plan of Action & Milestones (POA&M) for any unimplemented controls (that are eligible for a POA&M). The contractor then has 180 calendar days from the initial assessment date to close the POA&M and achieve a "Final" status. |
| 36 | #6.4.3 Attachment 1 - DRAFT - Performance Work Statement | PHI and PII are referenced in the PWS under HIPAA and DHA Data Sharing Agreement requirements, while CUI is referenced separately under NIST SP 800 171 and DFARS based requirements. | |
| • | The PWS does not explicitly classify PHI or PII as CUI. | ||
| • | Can it be clarified whether PHI and PII handled under this contract shall be treated as CUI for purposes of NIST SP 800 171, DFARS 252.204 7012, and CMMC Level 2 compliance? | Clear classification is necessary to ensure vendors design compliant technical and operational solutions. | Clarification: Yes. See definition of CUI in 32 CFR Part 2002. CUI, as it relates to a DoD contract, is Covered Defense Information (CDI), which includes Controlled Technical Information and Controlled Unclassified Information. See CDI definition in DFARS 252.204-7012. |
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