ETIS IV DRFP QA (4th Batch).pdf

Environmental Test and Integration Services

(ETIS) IV

Draft Request for Proposal Questions and Answers (Q&A)

80GSFC24R0012

July 9, 2025

Note: The questions/comments that were produced in this document were typed as they were submitted.

1. Question: Are all of the positions included in Enclosure EE included in the CBA?

Column header states "Collective Bargaining Agreement (CBA) Covered Labor Category"

Response: No, all the positions included in Enclosure EE are not in the CBA. The CBA specifies the job classifications it covers. A revised CBA (Attachment J – NG IBEW CBA Rev.1.pdf) was posted to the DRFP on November 1, 2024, on https://sam.gov.

2. Question: If all the labor categories listed in Enclosure EE are not covered by the CBA, will the Government be adding a prevailing Wage Determination for position such as Administrative Assistant, and Enclosure CC Computer Programmer, and designer?

Response: No, the CBA is the only wage determination that will be incorporated into this procurement.

3. Question: Will the Government please provide incumbent rates for the following historically union labor categories: Computer Programmer III, Computer Programmer IV, Designer III, and Designer IV?

Or, will the Government please confirm that these labor categories are not union and no incumbent rates exist? These labor categories are listed in the GPM.

Response: A revised CBA (Attachment J – NG IBEW CBA Rev.1.pdf) was posted to the DRFP on November 1, 2024, on https://sam.gov which provided rates for Computer Programmer III, Computer Programmer IV, Designer III, and Designer IV.

4. Question: Comment(s): There are labor categories in the GPM (i.e. Designer, Drafter, Janitor/Clean Room, Computer Programmer) not listed in the Enclosure EE historical data. Additionally, Enclosure EE data is confusing where same positions are listed as Exempt, Non-Exempt, and SCA.

Can the Government please reconcile and provide historical data that matches the GPM to allow offerors to more accurately propose the requirements?

Response: The Government provides contract historical data on labor categories utilized within the last twelve months for work completed by the Prime and Significant Subcontractor(s). For any labor categories not provided in Enclosure EE - Contract Historical Data, it can be assumed that those labor categories were not utilized within the last twelve months or not performed by the Prime or Significant Subcontractor. The Exempt, Non-Exempt, and SCA labor categories are appropriately classified, however all the positions included in Enclosure EE are not in the CBA. The CBA and contract historical data are provided in order to assist offerors in better understanding salary levels of the incumbent workforce. The labor categories in the GPM are those that the government considers essential to perform tasks orders under ETIS IV. Please note the Drafter labor category will be removed from Enclosure CC - GPM, as there are no anticipated hours for this labor category. Enclosure EE may be updated in the Final RFP.

5. Question: Will NASA identify historical OT hours?

Response: The Government will not be providing historical OT hours at this time.

6. Question: Due to the contract ceiling change, can the Govt please provide an updated GPM with hours prior to the final RFP?

Response: This request is noted. Due to the ETIS IV final RFP placed on hold until further notice while the Government reassesses the current strategy, any necessary revisions to the solicitation will be provided at the release of the Final RFP.

7. Question: DRFP L.31 states, “If applicable, Offerors may provide the experience or past performance of a parent or affiliated or predecessor company to an Offeror (including Joint Venture prime partner companies and/or a parent or affiliated company that is being otherwise proposed as a subcontractor on this effort) where the firm’s proposal demonstrates that the resources of the parent or affiliate or predecessor will affect the performance of the Offeror. The Offeror shall demonstrate that the resources of the parent or affiliate or predecessor company (its workforce, management, facilities, or other resources) shall be provided or relied upon for contract performance such that the parent or affiliate or predecessor will have meaningful involvement in contract performance.” We recommend the following alternate language: Offerors which are subsidiaries or affiliates of other business entities may submit the past performance of such other business entities for consideration, but such past performance shall be considered only to the extent that the proposal clearly demonstrates that the resources (e.g., financial resources, overall oversight and management, or other resources) of the other companies will meaningfully affect the performance of the proposed contract.

Response: The government will take this recommendation into consideration. Any revisions to the solicitation will be provided at the release of the Final RFP.

8. Question: Enclosure CC lists specific labor categories and hours for the different contract years. However, there is no direct link between this list and the rate matrix in Attachment B. Will the Government please clarify how contractors should map their proposed labor categories to those listed in Enclosure CC? Will the Government provide additional rate guidance to ensure consistency across all Offerors?

Response: See instructions in L.30 b (2) - the Prime and/or subcontractor(s) may propose direct labor category titles and PQs that match the GPM-Specified direct labor category titles and position descriptions. If the Prime and/or subcontractors are establishing new, direct labor category titles and PQs for this specific contract effort, then the labor category mapping should be performed in accordance with the Offerors Estimating and Accounting System. The Prime and Subcontractor shall map their categories to the GPM-Specified direct labor categories in Exhibits 2A or 2C. The Prime and Subcontractor's proposed labor categories titles and PQs shall be provided in Attachment B.

9. Question: Innovations to enhance the technical efficiency and cost performance of ETIS

IV and to bring in commercial work appear to be of significant importance. Will the Government consider adding a specific Section M evaluation factor to address innovations

Response: The Government is taking into consideration methods of incorporating innovations.

10. Question: Developing and maintaining currency in required technical skills is an important factor in maintaining work ready staffing. We do not know of any current program to address the specific needs of the GSFC ETIS technical workforce. Would GSFC consider a joint industry / regional economical and workforce development / non-profit initiative to develop a program that provides specific training in relevant mechanical, electrical and IT skills?

Response: It is at the Offeror's discretion to propose its best approach to the ETIS IV Final RFP.

11. Question: DRFP L.31 (a) states, “Prime Offerors shall furnish the information requested below for all of your most recent contracts (completed and ongoing) for similar efforts with a minimum average annual cost/fee incurred of $25M that your company has had within the last 5 years of the RFP release date.” DRFP M.6 states, “The overall confidence rating assigned to an Offeror’s Past Performance (see below) will reflect a subjective evaluation of the information contained in the oral presentation, if applicable;

written narrative; past performance evaluation input provided through customer questionnaires; and other references, if any, that the Government may contact for additional past performance information.” The ratings do not address how the quantity or quality of the relevant contract references will be evaluated for confidence. Without either a limitation on the quantity of contract references submitted or a definition of how the quantity of those submitted will be evaluated, the Past Performance submission and evaluation are subject to a prejudicial model. Few Offerors will have a portfolio of contracts to match the breadth of the Fortune 500 companies. This situation discourages competition from mid-tier companies and results in reduced competition. We recommend following requirement modification: Prime Offerors shall furnish the information requested below for a minimum of three (3) and maximum of five (5) contracts (completed and ongoing) for similar efforts with a minimum average annual cost/fee incurred of $25M that your company has had within the last 5 years of the RFP release date.

Response: The Government will take the recommendation into consideration and any revisions will be made in the Final RFP.

12. Question: DRFP L.31 states that Offerors are to provide “all of your most recent contracts (completed and ongoing) for similar efforts with a minimum average annual cost/fee incurred of $25M that your company has had within the last 5 years of the RFP release date.” This definition of recency is inconsistent with NASA’s acquisition strategy for similar services. We recommend the following revised definition: Recency is defined as performance occurring within the last three (3) years of the date of the issuance of the solicitation, except the ongoing programs must have begun no less than six (6) months from issuance of the solicitation.

Response: To allow for the greatest extent of competition the Government does not intend to reduce the requirements of the recency definition.

13. Question: DRFP M.6 states, “A ‘recent’ contract is a contract that is ongoing or completed less than 5 years prior to the issuance of this RFP.” This definition is too expansive and does not provide clarification for a minimum period of performance; an increased risk of a GAO protest is presented when the evaluation criteria are ambiguous.

We recommend the following revised definition: Recency is defined as performance occurring within the last three (3) years of the date of the issuance of the solicitation, except the ongoing programs must have begun no less than six (6) months from issuance of the solicitation.

Response: To allow for the greatest extent of competition the Government does not intend to reduce the requirements of the recency definition.

14. Question: The requirements for the Cost Volume’s submittal are reasonable for a Prime contractor. However, many small businesses (SB) are unfamiliar with the required level of detail and may not have in-place processes to comply with Cost Accounting Standards. The current definition of a Significant Subcontractor places an excessive burden on proposed SB subcontractors. L.30 (a) states, “For proposal purposes, Significant Subcontractor(s) is/are defined as the minimum number of subcontractor(s) when added to the prime, is equal to or greater than 80% of the total estimated cost.”

Please consider this revision to the Cost Volume definition of a Significant Subcontractor to align with the Past Performance volume and similar NASA RFPs: “For proposal purposes, Significant Subcontractor(s) is/are defined as having a contract value that equals or exceeds $25,000,000 over the entire contract performance period including option periods, excluding Government Pricing Model-Specified Other Direct Costs (ODCs).”

Support:

To fulfill the SB Subcontracting Plan participation goals, it is highly likely that a large business prime contractor will require a minimum of three SBs to meet the socio-economic niche goals. These SB subcontractors will likely also be proposed as providing labor services. If a Prime performs 70% of the contract value, the current definition will classify all SB subcontractors as “significant.” The referenced recent NASA solicitation (below) utilizes a definition that is more favorable to the SB community and is appropriately scaled to encourage meaningful involvement to enhance their operational experience.

Reference:

NASA RFP issued by Stennis Space Center (SSC) on April 18, 2024, with an estimated $117M/year value: Solicitation No. 80SSC024R0004, for Combined Operations, Services, Maintenance, and Infrastructure Contract (COSMIC)

L.I-11. MAJOR SUBCONTRACTOR (Excludes Cost/Price Definition of Major Subcontractor) For the proposal preparation purposes for Mission Suitability and Past Performance, “major subcontractor” is defined as subcontractor or Inter-/Intra-Work Transfer Authorizations (IWTA) having a contract value that equals or exceeds 10% over the entire contract performance period including option periods of total proposed contract value (TCV). For Cost/Price, a major subcontractor additional details can be found in

L.II-7.

L.II-7 COST/PRICE (VOLUME III) FACTOR 3 – COST/PRICE

Should the Government deem it necessary, comprehensive audits of the prime and/or Major Subcontractor proposals may be performed by the Offeror’s Cognizant Agency, an independent public accounting firm (pursuant to NFS 1815.404-2(a)(1)(F) “Use of Contractor to Perform Contract Audit Services”), or other Government agency. These audits may include business system audits such as audits of the Offeror’s accounting, estimating, purchasing, compensation, and/or other internal controls. Throughout the Cost/Price Volume instructions, the term “Offeror” is defined as the Prime Offeror which may be a Joint Venture. For proposal purposes, Major Subcontractor is defined as subcontractor or Inter-/Intra-Work Transfer Authorizations (IWTA) having a contract value that equals or exceeds $45,000,000 over the entire contract performance period including option periods, excluding IDIQ. Minor Subcontractors are defined as subcontractor having a contract value less than $45,000,000 over the entire contract performance period including option periods, excluding IDIQ.

Response: The Government is currently re-evaluating the acquisition strategy and will take these recommendations into consideration.

15. Question: L.29 B.8 states, “provide written Position Qualifications for each specific labor category proposed for contract performance.” The Government-provided Enclosure CC contains non-management personnel duties, education, and experience.

Please confirm that the requirement for the Mission Suitability factor is only to add position qualifications for the Offeror’s proposed management personnel to the non-management positions in Enclosure CC. If so, please consider excluding the Position

Qualifications table from the page limitation associated with the Mission Suitability Volume, as the content will be commonly presented in a multi-page table format.

Response: The RFP instructions require proposed position qualifications for all labor categories in the contract Attachment B. While Enclosure CC identifies requirements, each Offeror may propose their own unique position qualifications, as long as requirements are met.

16. Question: Further, Section B.9 (TCP requirements) describes how professional compensation that is unrealistically low or not in reasonable relationship to the various job categories, may adversely impact the offeror’s Mission Suitability evaluation or may result in rejection of the proposal (ref. FAR 52.222-46 and NFS 1852.231-71 that ensures coverage across all labor categories). The missing information in the CBA means that non-incumbent offerors will not be working in a fair and competitive proposal environment when developing their Cost/Price proposal for ETIS IV. Will the Government provide further information regarding the TCP of CBA employees to ensure that all offerors can propose realistic compensation?

Response: The Government posted a revised CBA (Attachment J – NG IBEW CBA Rev.1.pdf) to the DRFP on November 1, 2024, on https://sam.gov with unredacted information. Please note that additional revisions of the CBA may be provided in the Final RFP.

17. Question: Enclosure CC provides specific labor hours across contract years for various categories, but there appear to be inconsistencies with the hours provided in Exhibits 2-

12. Are these discrepancies in labor hours across different exhibits intentional? If not, how should Offerors reconcile them?

Response: The Government has revised Exhibits 2-12 by adding columns for hours and totals, where applicable.

18. Question: L.25 (2) states that Offerors are required to submit an Organizational Conflict of Interest (OCI) Plan with the proposal. M.2 (b)(1) states that inconsistencies in the OCI Plan compared to other sections of the proposal may render the entire proposal unacceptable. Will the Government please clarify how the OCI Plan will be evaluated in relation to the other proposal sections? What constitutes a “material inconsistency”?

Will the Government provide further guidance on how detailed the OCI Plan must be to avoid being classified as unacceptable?

Response: All areas of the proposal, including the OCI Plan, should be consistent with each other and should not contradict each other.

19. Question: What does the Government mean by "operational models"?

Response: The Government will be removing "operational models" language from the RFP cover letter.

20. Question: What does the Government mean by "differentiated approach"?

Response: The Government will be removing "differentiated approach" language from the RFP cover letter.

21. Question: Could NASA provide current information on the Years of Service of the employee population? Given the reductions in the GPM over the period of performance and current budget environment for NASA, there is a potential for reductions in force and non-incumbent offerors will have to accept a certain level of risk without being able to understand their potential liability for severance pay

Response: Information on the Years of Service of the employee population is not provided by the Government. The Government provides the experience required of non- Management Direct Labor Categories in Enclosure CC-GPM.

22. Question: Because this paragraph is part of A.1 (Scenario), it appears that risks should be related to the scenario. However, the requirement states "risks under this contract", implying a broader risk scope than just the scenario. Please clarify if risks are to be scenario-specific or contract-wide?

Response: The RFP will be revised in section A.1 Scenario, paragraph 5, from "risks under this contract " to "risks under this scenario". Scenarios are used as a representation of contract-wide approaches.

23. Question: Will NASA identify any shift hours and the typical premium paid and provide that information to all offerors?

Response: Shift hours shall be determined at the discretion of the successful offeror in conjunction with approval from the Government based upon the work being performed.

The Government has posted on https://sam.gov a revised Attachment J - NG IBEW CBA Rev.1.pdf with unredacted information for union labor categories.

24. Question: DRFP M.3 (c) states, “The Cost Factor is significantly less important than the combined importance of the Mission Suitability Factor and the Past Performance Factor.

As individual factors, the Mission Suitability Factor is more important than the Cost Factor which is more important than the Past Performance Factor.” While Cost as an evaluation factor is important, setting its individual evaluation as more important than the Past Performance Factor signals that NASA is looking for a low-cost contractor without experience. We recommend the following revised definition: The Cost Factor is significantly less important than the combined importance of the Mission Suitability Factor and the Past Performance Factor. As individual factors, the Mission Suitability

Factor is more important than the Past Performance Factor, which is more important than the Cost Factor.

Response: It is not the Government's intent to favor towards an offeror who is low-cost without experience. We will take this comment into consideration for the Final RFP.

25. Question: Will the Government consider revising the cost volume’s definition of

“significant subcontractor value” to exclude the non-labor (ODCs) related to procurement activities? For example, a revised definition would read as: “... is equal to or greater than 80% of the total estimated labor cost.”

Response: The Government will take into consideration this comment and any revisions will be reflected in the Final RFP.

26. Question: A. NPR 1620.2B, NPR 1620.3B, NPR 1660.1C is not public. My company does not have access to read those. How would you like us to proceed upon signing off on DD Form 254? We can strike those, you can give us access or controlled copies, sign off with notation “SBU -read upon access,” etc. B. I understand this is in draft format.

This is probably just formatting and very minor. NPR1600.1A Appendix C p.56 of 76 Table C1 is difficult to read. C. As I understand it, vendors should have established clearance at the time of proposal submittal. DD Form 254 directs to an instructions page, that I can’t easily find at this point in time. Later in the draft there is a reference to NASA FAR 1846.6. What is the exact formal address and/or email that we are we submitting this completed form to? ‘

Response: A. The DD Form 254 will be updated to remove NPR 1620.2B, NPR 1620.3B, and NPR 1660.1C at Final RFP release. B. The Government is looking into this issue, and it will be clarified at Final RFP release. C. DD Form 254 is to be submitted to the Contracting Officer and submission instructions are in the DRFP in section L.27 (c) (9), and the DD Form 254 with instructions will be provided at Final RFP release.