Q_A Roll Up Round 2 Comments Resolution Matrix 1.xlsx

Primer

STANDARDIZED COMMENT MATRIX PRIMER

S – Substantive (Material that appears to be incorrect, unnecessary, misleading, confusing or inconsistent)

CRM

Since the relevance requirements of the RFP focus on evaluating similarities in scope, magnitude, and complexity, the Government already has a more legitimate means to evaluate the complexity of the contracts than the NAICS classification, would the Government consider allowing past performance references for contracts performed in NAICS other than 561210 as long as the references include relevant performance such as OCONUS support, OCONUS construction, etc.? If bidders are restricted to using references for only contracts that are assigned NAICS 561210 (for the unrestricted pool), especially with the added restriction of only one task order per reference, some bidders (even incumbents) may not be able to show complete capability across all PWS areas despite successful performance.

As a specific example, OCONUS performance in NAICS 236220 - Commercial and Institutional Building Construction relates directly to PWS area 2.1.6.

The PWS has seven different task elements (2.1.1 – 2.1.7) each with different skill set requirements that might be legitimately be realized in different NAICS areas such as engineering services 541330 for the “design/build of electronics…ground support systems (2.1), or the requirement to “operate aircraft (fixed wing, rotary wing, aerostats, unmanned aerial vehicles (UAVS)” via NAICS 488190.

Limiting past performance references to NAICS 561210 unduly restricts bidders the ability to demonstrate they have successfully performed across all Operations and Logistics Support PWS areas.

Consider further that since NAICS code determinations are opinion-based decisions, there can be reasonable disagreement over the best fit for mixed-task IDIQ type contracts. For instance,

Would the Government please clarify that the naming convention for the PPI sheets in Volume I should still be: “Offeror Name-Volume Name-PPI X (e.g., XYZ Company-Past Performance Volume-PPI 3).” The Comments_Resolution_Matrix_(CRM).xlsx states that PPIs should be submitted as separate files within Volume 1, Past Performance, but the naming convention for these files has been removed from section L-6.1.1 Amendment 1. If submitting a zip file for the volume, number the PPIs consecutively (PPI 1, PPI 2, …)

In general, PPIs should be submitted in a manner that makes it readily apparent which volume and proposal they belong with.

4 Comments_Resolution_Matrix_(CRM).xlsx and Solicitation Amendment FA489022R00210001 SF 30.pdf p 40 40 L-6.3 213 and 391 Lines 213 and 391 of the Comments_Resolution_Matrix_(CRM).xlsx released with Amendment 1 indicates that contracts used as references must “correspond with the NAICS codes associated with the pool under which the offeror is bidding.”

L-6.3 states that “The Government may utilize references other than those identified by offerors in evaluation of offerors' Past Performance.”

When looking at these other sources (for an offeror in the unrestricted pool), does the Government intend to filter results from the FPDS, CPAR database, or other data repositories solely on efforts performed under 561210 and review information only associated with those awards in order to maintain the integrity of this requirement for both industry and government? If not, then would the Government consider removing the restriction of allowing only Past Performance references that are assigned a NAICS code of 561210? The Government’s evaluation of an offeror’s confidence rating in past performance is drawn from two source pools: (1) information obtained by the Government from any source open to them without restriction, and (2) information provided by industry but restricted to only awards made under NAICS code 561210 rather than from any work they were legitimately awarded by the federal government.

Clearly the Government has the duty and responsibility to look beyond what is submitted by the offeror to understand responsibility, but the confidence rating on past performance should not be based on an evaluation of any past performance that falls outside of NAICS 561210 since that is the boundary to which the offeror is being limited.

The Government could still require separate PPQs for each task order, as well as separate listings of value.

If the Government’s concern as stated is that “submission of an IDIQ or BPA by itself provides limited information for consideration,” wouldn’t the allowance for extra task order descriptions solve the problem better than limiting the number of task orders? Amendment 0001 revises L-6-1.1.2 to say that offerors “ may submit the MAIDIQ/SAIDIQ/BPA contract number AND ONE task order/BPA call or order thereunder to be counted as ONE contract reference. Other individual task orders/calls/orders will be considered as separate contract references.”

Most IDIQ contracts have multiple Task Orders relevant to different PWS areas. By counting each task order as one reference, the Government is severely restricting an offerors’ ability to describe the full depth of experience across the PWS and to achieve a rating of substantial confidence. The PWS 2.1 requirements are diverse --- finding one task order (even on the current CN&GT contract) to demonstrate capability across all areas is not possible. Since only five references are permitted total, the current requirement unduly restricts the ability to truly compete in Volume 1.

“L-7.4.3 Quality Management System (QMS). Provide the following:

1. Draft table of contents for the QMS

2. Proof of ISO9001 registration (Certificate)

3. A risk assessment matrix from a quality prospective that includes any risk considered moderate (medium) or above and the associated mitigation plan

4. Anticipated updates (e.g. planning, support, operations clauses) to your QMS to manage this effort.

5. The organizations quality management structure and associated resources to manage this IDIQ from a quality perspective.”

However, the amended solicitation has no change in L-7.4.3 and still reads: “L-7.4.3 Quality Management System (QMS). The offeror shall provide its approach to QMS, including:

Evidence of current ISO 9001 registration per PWS paragraph 3.1.1 IDIQ Quality Manual outline per PWS paragraph 3.4, Table 2 and paragraphs 3.4.6.5 - 3.4.6.5.1 that summarizes the offeror's QMS and identifies the offeror's approach for maintaining a Quality Control process/QMS that is compliant per PWS paragraph 3.1.1 and integrated into the overall management approach and meets the requirements of PWS paragraph 3.0 and Table 3, Services Summary.” The solicitation language requires the offeror to provide its approach to QMS. The answer in Line 181 (and 282, 283, 301, 384, and 386) is key to illustrating how the offeror will do so, requiring five areas to be included in the volume:

“L-7.4.3 Quality Management System (QMS). Provide the following:

1. Draft table of contents for the QMS

2. Proof of ISO9001 registration (Certificate)

3. A risk assessment matrix from a quality prospective that includes any risk considered moderate (medium) or above and the associated mitigation plan

4. Anticipated updates (e.g. planning, support, operations clauses) to your QMS to manage this effort.

5. The organizations quality management structure and associated resources to manage this IDIQ from a quality perspective.”

While these five areas were not specifically mentioned in the language of L-7.4.3, as amended, they are nevertheless required to be provided in the Technical Volume.

7 L-6 Instructions – Volume I, Past Performance (Factor 1) In the Q&A provided on 1 March with Amendment 1, in response to the following Question on NAICS codes (line 391) the government answered: YES

“Are the NAICS codes associated with the past performance references submitted by the offeror required to correspond with the NAICS codes associated with the pool under which the offeror is bidding? “

Neither the PPI or PPQ format have a field for NAICS codes, and in answer to the Question on CPARs (which have the NAICS code) on Line 351, the government reply was:

“No, the Government will not accept CPARS printouts in lieu of PPQs." Question 1: How will the government know which NAICS codes the submitted PP are under?

“Minor formatting changes are allowed; however, no changes in actual content in the PPI sheets are allowed.”

In addition on line 27, when asked if the offerors could add a section to the PPI for a “contract description”, the governments answer was not clear, stating “PPI forms currently allow for a description of the contract. Refer to Attachment 4, page 2 for PPI instructions refers to descriptions of contracts up to 500 characters.”

However, the only references in the PPI instructions to “500 characters” are in the fields for “Explaining the differences for Contract Values and for differences in Period of Performance”. Neither field seems appropriate for actually describing the scope of work done under the contracts?

It is noted that while the PPI does not have a field for “Contract Description or Scope, the template for the Past Performance Questionnaire, the first section to be filled out by the Offerors does have a “Scope of Work” section, paragraph 13. Does the government desire offerors to describe Contract Scope/Descriptions in the fields for “Explaining the differences for CONTRACT VALUES and for differences in Period of Performance”?

L-6.1.3 Joint Ventures. If the offeror is a Joint Venture, then offeror must meet the provisions of 13 CFR 125.8. Offerors that are Joint Ventures, including Mentor-Protege Joint Venture, must submit information to fully meet all requirements of the solicitation, including any capabilities, past performance, experience, business systems and certifications of the Joint Venture and that of individual partners of the Joint Venture. It is incumbent upon the JV offeror to affirmatively state in the proposal where it is specifically utilizing and relying upon a specific capability, past performance, experience, business system and certification of the specified partner. The Joint Venture shall provide a copy of their approved JV agreement, outlining the roles and responsibilities of all joint venture partners. Clarification on proposal preparation instructions. As long as the submitted agreement fully complies with the provisions of 13 CFR 125.8, then there are no further requirements.

capacity necessary to meet or exceed the stated requirements, submitting a letter of evidence to a line of credit (or other letter of commitment from a bank or financial institution) for at least $1M, indicating resources reserved and dedicated for this requirement. Offerors who do not submit evidence will be excluded from competition.

Attch 4 -- Section L Attachments (10Feb22) - L-2 PPI Sheet Instructions 39, 47

Will the Government please confirm?

If not confirmed, will the Government clarify where it requires Offerors provide this information and if it is subject to page count limitations?

Also see PWS Para 4.2.7.

41 PWS & Comments Resolution Matrix (CRM) Row 177 PWS Page 37 & CRM Row 177 PWS 4.2.7, Section 889 Compliance PWS Page 37 & CRM Row 177 The Government response in the CRM (row 177) regarding the NIST SP 800-171 compliance requirement was the following: "If the contractor cannot implement a requirement, they must document in their system security plan and plans of action the requirements that aren’t implemented, when they will be implemented, and make available for government review. At a minimum, the contractor will be required to complete a basic assessment, upload the resulting score to the Supplier Risk Management System (SPRS) and recertify every 3 years. " Question 1: Please confirm that the contractor will be considered compliant with the NIST SP 800-171 requirement if the contractor completes the “basic assessment” and recertifies it every three years?

Question 2: Where can contractors find a copy of this "basic assessment"?

Question 3: If the answer to Question 1 is "yes", please clarify whether contractors would still need to document their work-around for each of the 110 security requirements in a “system security plan?”

Question 4: When does the system security plan need to be submitted? The Contractor System would be allowed to maintain CUI data as long as they have authorization which would be based on a review of the security controls from the basic assessment. The three year authorization is the maximum time allowed between assessments, that period of authorization would be dictated by the Authorizing Official that approved the system.

The basic assessment is in reference to the security requirements listed in NIST Special Publication 800-171 Revision 2, paras 3.1. – 3.14. The contractor should review all the requirements and assess where they currently stand. There is no other checklist to use for compliance.

The contractors would need to provide a Plan of Actions and Milestones (POAM) for any requirements that are non-compliant.

The System Security Plan needs to be submitted prior to the system being brought online and having CUI information maintained by it. A way to be brought online quicker would be to apply for an Interim Authority to Test (IATT) but the basic assessment would need to be provided first.

CRM items #181, 281, 283, 301, 384, & 386 41 L-7.4.3 Quality Management System (QMS). Will the Government reconcile or revise the instructions and evaluation requirements for the QMS? There is conflicting language in the amended section L-7.4.3 and the CRM responses. Answers to 181, 281, 283, 301, 384, and 386 indicate new requirements 1-5 for the QMS. The solicitation language requires the offeror to provide its approach to QMS. The answer in Line 181 (and 282, 283, 301, 384, and 386) is key to illustrating how the offeror will do so, requiring five areas to be included in the volume:

“L-7.4.3 Quality Management System (QMS). Provide the following:

1. Draft table of contents for the QMS

2. Proof of ISO9001 registration (Certificate)

3. A risk assessment matrix from a quality prospective that includes any risk considered moderate (medium) or above and the associated mitigation plan

4. Anticipated updates (e.g. planning, support, operations clauses) to your QMS to manage this effort.

5. The organizations quality management structure and associated resources to manage this IDIQ from a quality perspective.”

While these five areas were not specifically mentioned in the language of L-7.4.3, as amended, they are nevertheless required to be provided in the Technical Volume.

Per solicitation section L-6.1.2.2 Relevancy, Offerors shall describe how each reference is relevant (individually and/or in aggregate) in demonstrating the ability to perform the full range of CN> services capabilities IAW ID/IQ PWS requirements for the NAICS code being proposed against.

Will the Government please confirm consideration of past performance under any NAICS where the offeror substantiates relevancy per the ID/IQ PWS requirements for the NAICS code being proposed against?

We appreciate the Government’s deliberate choice of NAICS codes 561210 and 611430 to determine the bidding pools’ size standards and procurement description. Using the NAICS code to restrict allowable Past Performance Information so narrowly eliminates and precludes multiple seasoned Counter Narcotics services providers from fair and equitable competition.

The Government, including the Department of Defense (DOD), routinely issues contracts and task orders supporting training programs that mirror and support the CN&GT Training Support Services requirements making them directly relevant to this opportunity. These include, for example:

Govt. Answer: The PPI template has been revised for the offeror to include the NAICS code at the beginning of Section I.

Govt. Answer: The template is less than one page, not including the instructions (which are not to be submitted with the PPI). However, the PPI length is being expanded to 2 pages to accommodate the breakout of Orders awarded on an ID/IQ or BPA if used as a reference.

As the single contract reference, the Government will evaluate only the ONE submitted order/call under the IDIQ/BPA and is under no obligation to conduct evaluation on other and all orders/calls under the IDIQ. Similarly, offerors are not required to submit documents (PPI information sheet, consent letter, PPQ) on other and all orders/calls.

The contractor may submit other additional task/delivery orders/calls, but each will be counted as separate contract references (and will require documents (PPI information sheet, consent letter, PPQ).