Section_M _Draft_Solicitation.pdf
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- Tinker AFB--Multiple Award Construction Contract Federal contract opportunity
- Solicitation number
- FA8101-15-R-0004
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Draft Section M- (Evaluation Criteria)
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SECTION M - EVALUATION FACTORS FOR
AWARD
1.0. SOURCE SELECTION (SS)
1.1 Basis for Contract Award
This acquisition will utilize tradeoff source selection procedures, with technical proposals, to make an integrated assessment for a best value award decision. Tradeoffs will be made only between past performance and price among those offerors who have been determined technically acceptable. Award will be made to the offeror who is deemed responsible in accordance with the Federal Acquisition Regulation (FAR) Part 9, as supplemented, whose proposal conforms to the solicitation’s requirements (to include all stated terms, conditions, representations, certifications, and all other information required by Section L of this solicitation) and is evaluated to represent the best value to the Government.
This may result in an award to a higher rated, higher priced offeror, where the decision is consistent with the evaluation factors and the source selection authority (SSA) reasonably determines that the technically acceptable proposal and superior past performance of the higher price offeror outweighs the price difference with lower priced offerors. While the Government source selection evaluation board (SSEB) and the SSA will strive for maximum objectivity, the Source Selection process, by its nature, is subjective, and therefore, professional judgment is implicit throughout the entire process.
This source selection is conducted in accordance with Federal Acquisition Regulation (FAR) Part 15.3, Contracting by Negotiation, as supplemented by the Defense Federal Acquisition Regulation Supplement (DFARS), the Air Force Federal Acquisition Regulation Supplement (AFFARS), DoD Source Selection Procedures 04 Mar 2011, and Air Force Mandatory Procedures 5315.3. These regulations are available electronically at the Air Force (AF) FARSite, http://farsite.hill.af.mil.
1.2 Number of Contracts to be Awarded
The Government intends to select up to four (4) contractors for award. However, the Government reserves the right not to award, depending on the quality of the proposals and prices submitted and the availability of funds.
1.3 Correction Potential of Proposals
The Government will consider the correction potential of any proposal aspect evaluated as unacceptable. The judgment of such correction potential is within the sole discretion of the
SECTION M FA8101-15-R-0004 (12 Pages) Page 1 http://farsite.hill.af.mil/vffara.htm http://farsite.hill.af.mil/
Government. If an aspect of an offeror's proposal is not considered correctable, or if the amount and/or complexity of the corrections needed to meet the Government requirement requires a major proposal revision, the offeror may be eliminated from the competitive range.
1.4 Rejection of Offers
The Government may reject any evaluated proposal that fails to adequately address a significant portion of the requirement or contract terms and conditions. This may include rejection of a proposal that does not demonstrate an adequate technical understanding of the requirement and/or displays a fundamental lack of competence or failure to comprehend the technical complexity and risk of the program. The Government may review all volumes of the proposals to ensure adequate resources to perform the proposed technical approach.
1.5 Competitive Range Determination
During the evaluation process multiple competitive range determinations may be made that eliminate offerors from the competition. The competitive range determination can be based on Factor 1-Technical, Factor-2 Past Performance, Factor 3-Price, or a combination of the 3 factors.
A competitive range determination may eliminate offerors based on their initial proposal evaluation results, after discussions, prior to issuance of the final proposal revision (FPR) request, or for efficiency. If offerors are excluded from the competitive range they may request a debriefing IAW FAR 15.505.
1.6 Discussions
The Government intends to award without discussions, but reserves the right to conduct discussions if necessary. Therefore, it is imperative that offerors submit their best terms initially.
However, if during the evaluation period it is determined to be in the best interest of the Government to hold discussions, offeror responses to evaluation notices (ENs) and the FPR will be considered in making the source selection decision. If the Government issues a request for FPR, offerors must incorporate their responses to ENs for Volume I-Technical, Volume III- Price, and Volume IV-Contract Documentation in the FPR in order to be considered in the final evaluation. Failure to include EN responses in the FPR may result in a final “unacceptable” technical rating, or otherwise make your company ineligible for award. Offeror responses to ENs for Volume II-Past Performance shall not be included in the FPR and will automatically be considered in the final evaluation.
1.7 Solicitation Requirements (Terms and Conditions)
Offerors are required to meet all solicitation requirements, such as terms and conditions, representations and certifications, and Statement of Work (SOW) requirements, in addition to those identified as factors and subfactors. Failure to comply with the terms and conditions of the solicitation may result in the offeror being ineligible for award. Offerors must clearly identify any exception to the solicitation terms and conditions and must provide complete supporting rationale.
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2.0. EVALUATION FACTORS
2.1 Evaluation Factors and Subfactors
The Government will assess the offeror’s proposal to ensure it meets the requirements and intent of the SOW. Each offeror’s proposal will be evaluated against the below criteria.
2.1.1 Evaluation Factors
Factor 1: Technical
Subfactor 1: Special Standard of Responsibility (SSR) Subfactor 2: Bonding Capability
Factor 2: Past Performance Factor 3: Price
2.1.2 Relative Importance of Factors and Subfactors
For this solicitation, technical acceptability is a prerequisite to the tradeoff between price and past performance. For all technically acceptable proposals, Factor 2-Past Performance is considered to be significantly more important than Factor 3-Price. However, price substantially contributes to the award decision.
2.1.3 Evaluation Methodology
The evaluation will be conducted as follows:
The Government will evaluate all factors concurrently for all proposals. Initial ratings for all factors will be established for each offeror in determining the competitive range. The Government technical evaluation team will evaluate the technical proposals on a pass/fail basis, assigning ratings of Acceptable, or Unacceptable. The technical proposals shall be evaluated against the subfactors listed in paragraph 3.0 below. Past Performance will be evaluated as described in paragraph 4.0 below. Price will be evaluated as described in paragraph 5.0 below.
For the award decision, the SSA will assess the Past Performance ratings and Price for all technically acceptable offers to make an integrated assessment of which offeror provides the overall best value.
NOTE: in accordance with FAR 52.215-1(f)(4) and FAR 15.306(c), for purposes of efficiency, the Government reserves the right to establish a competitive range composed of a number of offers determined to be sufficient for efficient evaluation and contract award. The Government may determine not to establish a competitive range based on pricing for purposes of efficiency at this point.
3.0. FACTOR 1 – TECHNICAL
Each subfactor within the technical factor will receive one of the ratings described below based on the criteria listed below. Individual subfactor ratings will be used to determine the overall technical acceptability of each offeror. To be determined technically acceptable at the factor
SECTION M FA8101-15-R-0004 (12 Pages) Page 3 level, the offeror must be rated acceptable in each subfactor. A final unacceptable subfactor assessment will determine an overall technical unacceptable rating.
Rating Description
Acceptable Proposal clearly meets the minimum requirements of the solicitation.
Unacceptable Proposal does not clearly meet the minimum requirements of the solicitation.
3.1 Subfactor 1: Special Standard(s) of Responsibility
IAW FAR 9.104-2, there are twelve (12) Special Standard of Responsibility (SSR) required by this RFP. The offerors must provide current Licenses and Accredited Professional (AP) Certificates of certified individual currently on staff of the prime contractor, or currently on staff of the primary A-E Firm subcontractor (Letter of Intent is acceptable but, must be provided with applicable license/certification) for the following disciplines:
1. Architect- License
2. Civil Engineer- License
3. Mechanical Engineer- License
4. Electrical Engineer- License
5. Structural Engineer- License
6. Fire Protection Engineer- License
7. Geotechnical Engineer- License
8. Environmental Engineer- License
9. Interior Designer- License
10. LEED Professional- Certification
11. Land Surveyor- License
12. Design Program Manager- License, and Resume proving 10 years of experience
3.2 Subfactor 2: Bonding
The Government will assess the offeror’s proposed proof of bonding. To be acceptable, the offeror must provide current and valid proof in the form of a letter from an A.M. Best Surety with a rating of --- A, which guarantees the offeror is eligible to be bonded for a minimum project amount of $10 million and an aggregate bonding limit of $20 million. The Government will verify the bonding surety rating via A.M. Best website (http://www.ambest.com/). If the
SECTION M FA8101-15-R-0004 (12 Pages) Page 4 http://www.ambest.com/ offeror is acceptable in the initial proposal, the offeror will not be required to submit any updates or renewals during the evaluation process.
4.0. FACTOR 2 – PAST PERFORMANCE
The past performance evaluation assesses the degree of confidence the Government has in an offeror’s ability to meet the SOW requirements, based on a demonstrated record of performance.
Past performance for parent companies, other divisions, etc. will only be considered if those companies are proposed to perform part of the current effort, in which case, their past performance will be evaluated for the portion of effort they are proposed to perform.
4.1 Ratings
The past performance factor will receive one of the following performance confidence assessments described in the Department of Defense (DoD) Source Selection Procedures, paragraph 3.1.3.3, Table 5 – Performance Confidence Assessments:
TABLE 5- PERFORMANCE CONFIDENCE ASSESSMENTS
Rating Description
SATISFACTORY
CONFIDENCE
Based on the offeror’s recent/relevant performance record, the Government has a reasonable expectation that the offeror will successfully perform the required effort.
LIMITED CONFIDENCE
Based on the offeror’s recent/relevant performance record, the Government has a low expectation that the offeror will successfully perform the required effort.
NO CONFIDENCE
Based on the offeror’s recent/relevant performance record, the Government has no expectation that the offeror will be able to successfully perform the required effort.
UNKNOWN CONFIDENCE
(Neutral)
No recent/relevant performance record is available or the offeror’s performance record is so sparse that no meaningful confidence assessment rating can be reasonably assigned.
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Note: With regards to the best value award decision, all offerors rated as “Satisfactory Confidence” will be considered equal for the Past Performance Factor.
4.2 Evaluation Process
Performance confidence is assessed at the overall past performance factor level after evaluating aspects of the offeror’s recent past performance. The contractor shall focus on performance that is relevant to construction projects in which all or a mixture of the required technical licenses in paragraph 3.1 (above) were utilized to complete a successful design-build effort. The Government may consider past performance in the aggregate in addition to on an individual contract basis. In conducting the past performance evaluation, the Government reserves the right to use both the information provided in the offeror’s past performance proposal volume and information obtained from other sources, such as the Past Performance Information Retrieval System (PPIRS) or similar systems, Defense Contract Management Agency (DCMA) and commercial sources.
4.2.1 Recency Assessment:
An assessment of the past performance information will be made to determine if it is recent. To be recent, the offeror must have performed during the past three years from the date of issuance of this solicitation. If any part of the performance falls within the above timeframe, the contract in its entirety may be evaluated for past performance. Past performance information that fails this condition will not be evaluated.
4.2.2 Relevancy Assessment:
The Government will conduct an in-depth evaluation of all recent performance information obtained to determine how closely the projects performed under those contracts relate to the Tinker MACC requirement.
Consideration will be given to things such as similar type of work, similar complexity of the effort, breadth and depth of skills, similar contract type, magnitude and schedule. A relevancy determination of the offeror’s (including joint venture partner(s) and major/critical subcontractor(s)) past performance will be made based upon the aforementioned considerations.
In determining relevancy for individual contracts, consideration will be given to the effort, or portion of the effort, being proposed by the offeror, teaming partner, or subcontractor whose contract is being reviewed and evaluated. The Government will consider the portion of the effort accomplished on previous/current contracts compared to the portion to be performed on the proposed effort. For example, past performance of a subcontractor for program management will only be considered if that same subcontractor is to perform program management on the proposed effort.
The Government will use the following degrees of relevancy described in the DoD Source Selection Procedures, paragraph 3.1.3.1, Table 4, when assessing recent, relevant contracts:
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Degree Description
RELEVANT
(R)
Present/past performance effort involved similar scope and magnitude of effort and complexities this solicitation requires.
SOMEWHAT RELEVANT
(SR)
Present/past performance effort involved some of the scope and magnitude of effort and complexities this solicitation requires.
NOT RELEVANT
(NR)
Present/past performance effort involved little or none of the scope and magnitude of effort and complexities this solicitation requires.
Scope, magnitude and complexity will be assessed based on the prime or subcontractor/teaming partners proposed role or effort as it relates to the past performance effort. The Government may or may not utilize all or some of the following to determine the elements examined within scope, magnitude, complexity, and price:
Scope: The Tinker AFB MACC requirement consists of the execution of a broad range of construction projects such as: Design-Build, Conceptual Design (35%), 100% Government Design, and Construction Only. Contractor will be required to furnish all materials, equipment, transportation, and personnel necessary to manage and accomplish projects. In general, contractors would be expected to accomplish a wide variety of tasks in the industry trade including, but not limited to: new construction of buildings and structures, alteration and repair of buildings and structures, and specialty construction.
Magnitude: Relevancy in regard to magnitude may be assessed based on, but not limited to, the number of construction projects completed per year, and contract value.
Complexity: Relevancy in regard to complexity may be assessed based on specific similarities between a given past performance effort and the Tinker AFB MACC requirement. Areas of consideration also include:
• Key Personnel: The offeror’s performance record includes design-build construction experience utilizing key personnel such as a Design Program Manager, Project Superintendent, Civil Engineer, Architect, Safety Manager, and Quality Control Manager.
• Bonding: The offeror’s performance record includes submission of bonding appropriate for the construction project value.
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Price Assessment Past Performance Relevancy: Relevancy in regard to price will be assessed primarily based on similarity between contract type (FFP) of previous efforts as compared to this requirement.
4.2.3 Performance Quality Assessment:
The Government will consider the performance quality of recent, relevant efforts. The quality assessment consists of an in-depth evaluation of the past performance questionnaire responses, PPIRS information, Contractor Performance Assessment Reports (CPARS), interviews with Government customers and fee determining officials and, if applicable, commercial clients. It may include interviews with DCMA officials or other sources known to the Government. The quality assessment may result in positive or adverse findings. Adverse is defined as past performance information that supports a less than satisfactory rating on any evaluation element or any unfavorable comment received from sources without a formal rating system. For adverse information identified, the evaluation will consider the number and severity of the problem(s), mitigating circumstances, and the effectiveness of corrective actions that have resulted in sustained improvements when determining the quality assessment. Process changes will only be considered when objectively measurable improvements in performance have been demonstrated.
The Government will use the following quality levels when assessing recent, relevant efforts:
Quality Assessment Description
SATISFACTORY (S)
(GREEN)
Performance meets contractual requirements. The contractual performance of the element being assessed may contain some minor problems for which corrective actions taken by the contractor appear, or were, satisfactory.
MARGINAL (M)
(YELLOW)
Performance does not meet some contractual requirements.
The contractual performance of the element being assessed reflects a serious problem for which the contractor has not yet identified corrective actions or the contractors proposed actions appear only marginally effective or were not fully implemented.
UNSATISFACTORY (U)
(RED)
Performance does not meet most contractual requirements and recovery is not likely in a timely manner. The contractual performance of the element being assessed contains serious problem(s) for which the contractor’s corrective actions appear, or were, ineffective.
UNKNOWN (UK)
Unknown Performance rating due to lack of sufficient information to assign a rating.
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4.2.4 Assigning Ratings:
As a result of the relevancy and quality assessments of the recent contracts evaluated, offerors will receive an integrated performance confidence assessment rating based on the definitions provided in paragraph 4.1 above. The rating is not based on a quantitative analysis. Although the past performance evaluation focuses on performance that is relevant to scope, magnitude, complexity, and price assessment, the resulting performance confidence assessment rating is made at the factor level and represents an overall evaluation of contractor performance. More recent performance may have a greater impact on the performance confidence assessment than less recent performance. Offerors without a record of relevant past performance, or for whom information on past performance is not available, will not be evaluated favorably or unfavorably on past performance and, as a result, will receive an "Unknown Confidence" rating for the past performance factor. More relevant performance will have a greater impact on the performance confidence assessment than less relevant effort. A strong record of relevant past performance may be considered more advantageous to the Government than an "Unknown Confidence" rating. Likewise, a more relevant past performance record may receive a higher confidence rating and be considered more favorably than a less relevant record of favorable performance.
5.0. FACTOR 3 – PRICE
5.1 General Information for Price Evaluation
Based on previous workload history, the Government has provided estimated amounts for each line item in the Not to Exceed (NTE) Coefficient Matrix found in ITO Attachment 1.6 of the RFP. These estimates are strictly used to calculate the Total Evaluated Price (TEP). The Government is in no way obligated to order these amounts after contract award. The Government shall evaluate the TEP of all Technically Acceptable Offerors. This price roll-up is based on the specific line item calculation methodology provided in the NTE Coefficient Pricing Matrix.
These calculations include all evaluation periods: Base Year, Three , One-Year Options, and a Six-Month “Option to Extend Services” . Each Offeror’s price proposal will be evaluated based on the TEP as calculated in the solicitation NTE Coefficient Pricing Matrix. ITO – 1.6 of Section L. The calculation methodology for TEP is provided below in Section M paragraph 5.5.2.
NOTE: The proposed coefficients will be utilized in the execution of contract delivery orders and are considered not to exceed (NTE) coefficients applicable to provided mandatory RS Means breakouts IAW SOW paragraph 1.8.4.
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5.2 Price Reasonableness and Realism
The proposed prices will be evaluated for reasonableness. Analysis of price proposals will be performed using one or more of the techniques defined in FAR 15.404-1 in order to determine price reasonableness. Reasonableness must represent a price to the Government a prudent person would pay in the conduct of competitive business. Normally, price reasonableness is established through adequate price competition, but may also be determined through price analysis techniques as described in FAR 15.404-1. Price proposals will be compared against other pricing proposals, as well as compared to the Independent Government Estimate (IGE).
Price proposals will be reviewed for compliance with terms and conditions of the solicitation, reviewed for mathematical accuracy in accordance with the NTE Coefficient Pricing Matrix, and pricing data will be compared with each Offeror’s technical proposal.
Should the Contracting Officer determine proposed prices appear unreasonable or unrealistic (the possibility an Offeror does not fully understand the requirement), the Offeror may be required to support price reasonableness or price realism via data other than cost or pricing data.
Unrealistically low prices may be grounds for eliminating a proposal from the competition based on an apparent lack of adequate understanding of the requirement or a failure to comprehend the complexity and risks of the program. Pricing will also be evaluated for completeness which is considered an aspect of reasonableness. Pricing for all line items as required in the NTE Coefficient Pricing Matrix is necessary for a determination of complete pricing.
5.3 Unbalanced pricing
Offeror’s proposals will be reviewed for unbalanced pricing. The Government will evaluate any supporting information provided by the offeror explaining variances that appear unbalanced.
Evaluated offers that are determined to be unbalanced may be deemed ineligible for award by the Contracting Officer if a determination is made that lack of balance poses an unacceptable risk to the Government. Unbalanced pricing exists when, despite an acceptable total price, the price of one or more line items is significantly over or understated as demonstrated by application of price analysis techniques, such that:
a) There is reasonable doubt the offer would result in the lowest overall cost to the Government, even though it is the lowest priced offeror; or
b) The offer is so grossly unbalanced; its acceptance would be tantamount to allowing an advanced payment.
Unbalanced pricing reflects pricing characterized as mathematically unbalanced and materially unbalanced. Proposed pricing will be evaluated for balance by line items across performance years to ensure costs are not inappropriately allocated in certain years, such as the Base Year.
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5.4 Data Other than Certified Pricing Data
If requested by the CO, data other than certified pricing data shall be evaluated to support a determination of reasonable, balanced, and realistic pricing. This information will only be requested if all other sources have been insufficient to support a determination of reasonable, balanced, and realistic pricing.
5.5 Total Evaluated Price (TEP)
Evaluation of proposed pricing will be based on review of pricing provided in ITO – Attachment
1.6 NTE Coefficient Matrix. The average annual cost in ITO – Attachment 1.6 NTE Coefficient Matrix are for evaluation purposes only and does not obligate the Government in any way.
The offeror’s pricing proposals will be reviewed for compliance with Section L pricing instructions. Proposed pricing evaluated as the TEP is required IAW Section L, paragraph 5.0 and all subparagraphs.
The TEP will be calculated as the summation of the “Estimated Evaluated Price (EEP) for each contract period” including Base Year , Three, One-Year Option Periods, and a Six-Month “Option to Extend Services”.
TEP will be used for evaluation purposes only. Evaluation of options shall not obligate the Government to exercise such options. Should discrepancies exist in unit prices between the hard copy of ITO – Attachment 1.6 NTE Coefficient Pricing Matrix and any electronic copy of ITO – 1.6, the hard copy will be used for the TEP.
5.5.1 NTE Coefficient Pricing Matrix
Proposed unit prices shall be input into the solicitation NTE Coefficient Pricing Matrix (ITO – 1.6, Section L). Should discrepancies exist in unit prices between the hard copy and electronic copy of the price model, the hard copy will be used for the TEP. Coefficients shall be utilized as NTE rates inclusive of bonding, overhead, general and administrative, profit and additional costs identified in SOW paragraph 1.8.4.10.
5.5.2 Calculation Methodology of the TEP
The TEP will be calculated as the sum of the “Estimated Evaluated Price (EEP) for each contract period” including the Base Year plus, Three, One-Year Option Periods, and a Six- Month “Option to Extend Services” (SUM= EEP Basic Year + EEP Option Year I + EEP Option Year II + EEP Option Year III+ EEP Extension of Services). EEP will be calculated as the summation of each line item Extended price for the contract period. The Extended price is calculated by multiplying the Average Annual Cost by the proposed NTE Coefficient (Extended Price =Average Annual Cost X NTE Coefficient).
5.5.3 Rounding
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Compliance with instructions regarding rounding, as described in Section L paragraph 5.3, will be verified during evaluation. If proposed pricing is not provided in accordance with instructions, the Government will apply rounding format as specified.
5.5.4 Annual Price Changes
Escalation rates or annual pricing changes will be reviewed to ensure balanced pricing. Annual escalation greater than 5% should be fully explained and justified.
5.6 Price Assumptions/Basis of Estimate Used in Development of Proposed Pricing The Government will review information provided in Section 1 of the Price Volume regarding cost assumptions utilized in the development of proposed pricing. Such information will be used to understand the offeror’s proposed pricing basis of estimate. Coefficients shall be utilized as Not to Exceed (NTE) rates inclusive of Bonding, Overhead, General and Administrative and Profit rates. Additionally, these assumptions help provide support for the Government’s determination of reasonable, balanced, and realistic pricing.
5.7 Other Documentation Review
In reviewing proposed prices, all additional information from the Price Volume will also be considered. Offerors may provide any additional data other than certified pricing data as believed necessary to support, justify or clarify their proposed pricing.
6.0. CONTRACT DOCUMENTATION
6.1 Volume IV Documents
The offerors shall furnish all documents for review and acceptance that are listed in Section L, paragraph 6.0 and all subparagraphs.
SECTION M FA8101-15-R-0004 (12 Pages) Page 12
| 1.0. SOURCE SELECTION (SS) |
| 1.1 Basis for Contract Award |
| 1.2 Number of Contracts to be Awarded |
| 1.3 Correction Potential of Proposals |
| 1.4 Rejection of Offers |
| 1.5 Competitive Range Determination |
| 1.6 Discussions |
| 1.7 Solicitation Requirements (Terms and Conditions) |
| 2.0. EVALUATION FACTORS |
| 2.1 Evaluation Factors and Subfactors |
| 2.1.1 Evaluation Factors |
| 2.1.2 Relative Importance of Factors and Subfactors |
| 2.1.3 Evaluation Methodology |
| 3.0. FACTOR 1 – TECHNICAL |
| 3.1 Subfactor 1: Special Standard(s) of Responsibility |
| IAW FAR 9.104-2, there are twelve (12) Special Standard of Responsibility (SSR) required by this RFP. The offerors must provide current Licenses and Accredited Professional (AP) Certificates of certified individual currently on staff of the prime cont... |
| 1. Architect- License |
| 12. Design Program Manager- License, and Resume proving 10 years of experience |
| 3.2 Subfactor 2: Bonding |
| 4.0. FACTOR 2 – PAST PERFORMANCE |
| 4.1 Ratings |
| 4.2 Evaluation Process |
| 4.2.1 Recency Assessment: |
| 4.2.2 Relevancy Assessment: |
| 4.2.3 Performance Quality Assessment: |
| 4.2.4 Assigning Ratings: |
| 5.0. FACTOR 3 – PRICE |
| 5.1 General Information for Price Evaluation |
| 5.2 Price Reasonableness and Realism |
| 5.3 Unbalanced pricing |
| 5.4 Data Other than Certified Pricing Data |
| 5.5 Total Evaluated Price (TEP) |
| 5.5.1 NTE Coefficient Pricing Matrix |
| 5.5.2 Calculation Methodology of the TEP |
| 5.5.3 Rounding |
| 5.5.4 Annual Price Changes |
| 5.6 Price Assumptions/Basis of Estimate Used in Development of Proposed Pricing |
| 5.7 Other Documentation Review |
| 6.0. CONTRACT DOCUMENTATION |
| 6.1 Volume IV Documents |
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