HCaTS_Draft_RFP_Industry_Questions_(05202015)_(1).pdf

Question Answer Category / Topic

If the offeror possesses a Top Secret Facility Clearance, can they claim the points for

Secret and Top Secret since they exceed the 'Secret' Facility Clearance level requirements?

This scoring element will be removed. Accreditation

Will the government also accept the Associate Certified Coach (ACC) certification for

HCaTS key personnel?

We have removed the Contractor Key Personnel scoring element due to Industry Feedback. The final RFP will only have company-wide accreditations.

Accreditation

Additional points are awarded for several certifications that are relevant to the performance of HCaTS related services (ISO 9001, CMMI, etc), but the sustainability certification isn't relevant to the offerors ability to effectively perform human capital and training services. Can the government explain how sustainability certification is relevant to an offerors ability to perform services under the HCaTS contract?

The HCaTS PMO has removed ISO 14001:2004 as an accreditation and it will not appear in the final RFP.

Accreditation

Many training & learning professionals have degrees that are not specifically in

"Instructional Systems Design" but are focused on design & development of learning experiences for adult learners. Will the government accpet alternative degrees in areas such as: Education, Adult Learning, Instructional Technology, or Adult

Education / Training & Development?

We have removed the Contractor Key Personnel scoring element due to Industry Feedback. The final RFP will only have company-wide accreditations.

Accreditation

Many human capital and training experts have degrees in releavnt fields that are not specifically identified as human resources or human capital. Will the government accept degrees in disciplines such as: Industrial/Organizational Psychology, Organization Development, Management, or Business Mangement/Administration?

We have removed the Contractor Key Personnel scoring element due to Industry Feedback. The final RFP will only have company-wide accreditations.

Accreditation

P.53, Section H.6.1 Question: Please confirm whether or not the small business must have a recent DCAA audit. Specifically, being audited is outside the control of a

(small) business as it’s the government’s decision who and when to audit, and many small firms have never received an audit. Our accounting system (Deltek) is capable of being fully compliant with DCAA’s requirements for an acceptable accounting system. Please confirm if the government is requiring small businesses that bid on this effort to have had an audit prior as a condition of bidding on (or being awarded this) IDIQ or if either of the following would be acceptable: (1) An outside firm conducts an audit of the potential awardee following the same audit requirements as

DCAA and presents a determination of findings to the government, or (2) The government notifies DCAA to come in and audit those businesses without audits prior to making a final award.

All Offerors that are considered for award based on being in the

Top 40 proposals per Pool will have the option to have their accounting system audited by DCAA. If an Offeror has an accounting system that was audited by the DCAA within the last three years and there have been no changes, their system will not need to be audited again. Only Offerors with audited accounting systems will be able to compete for cost-reimburseable type work at the task order level.

Accreditation

H.6.5 EVMS is primarily used on large production contracts. Since this contract is focused on HCaTS, it is not reasonable to use attainment of EVMS certification as a discriminator. Recommend elimination of EVMS as a scoring factor.

Although the FAR requires the use of EVMS in major acquisitions for IT/systems development, there may be task orders issued under

HCaTS that can benefit from EVMS, especially under KSA 3.

Accreditation

Please note: All information is subject to change. We are sharing this information now for transparency. Please continue to check the HCaTS interact blog for additoinal updates

HCaTS Draft Request for Proposal (DRFP) Q&A

Tuesday, May 19, 2015

H.6.5 The use of commercially integrated EVMS systems, such as DELTEK’s EVMS module, provide similar benefits as a self-administered ANSI/EIA Standard-748 certified system. Will the HCaTS team consider commercially integrated business system EVMS tools, such as Deltek’s ERP EVMS module, for points under L.5.4.4?

No Accreditation

H.6.8 ISO 14001:2004 specifically allows for self-certification. Companies working with the certification, therefore, may or may not have a 3rd party providing independent validation of the use of these processes and yet this may make a difference in scoring. Recommend acceptance of self-certification or removing this certification from the scoring evaluation.

This Accreditation has been removed. Accreditation

H.6.2-5: We recommend removing the award of additional points for the possession of audited estimating and purchasing systems as well as forward pricing rates agreements (FPRA), forward pricing rate recommendations (FPRP), and approved billing rates. We appreciate that the HCaTS PMO is not considering these as mandatory or minimum requirements; however, Offerors who have met these criteria should not be considered more favorably. These additional equirements are applicable to cost reimbursable contracts and have no bearing on the ability of

Offerors to successfully deliver on other types of contracts. We understand that the

HCaTS PMO is seeking to identify objective evaluation criteria by which to differentiate contractors, but we do not believe these are objective criteria that demonstrate the quality of the service being provided. These additional criteria will bias the selection of contractors based upon criteria that do not relate to value provided to the government for non-cost-reimbursable contract types. We propose that the HCaTS PMO categorize contractors based on cost accounting standards criteria; but do not limit those contractors that do not intend to bid on cost-reimbursable from being eligible for award.

This recommendation was considered but the RFP will not be amended.

Accreditation

H.6.1: We recommend removing the requirement that Offerors possess a DCAA-audited accounting system. This mandatory requirement may disqualify Offerors with strong relevant capabilities from participating and reduce competition at the task order level. We recognize that there are instances in which Cost Plus contracts are necessary and that a certified accounting system supports these contracts, but a large number of task orders issued under HCaTS will not fit under this description and are likely to be firm fixed price. There are also challenges associated with cost reimbursable contracts, such as added administrative costs and constrained access to an Offeror’s full complement of services. As a result, we recommend only requiring cost reimbursable contract pricing at the task order level, when necessary. Cost reimbursable contract pricing could become a feature of the IDIQ contract, but not a requirement or evaluation criterion. We propose that HCaTS PMO categorize contractors based on cost accounting standards criteria; but do not limit those contractors that do not intend to bid on cost-reimbursable from being eligible for award. This approach will provide contracting agencies the flexibility of when (and when not) to require cost reimbursable contract pricing, while expanding competition.

This recommendation was considered. Accreditation

L.5.4.3 Credit is applied for the scoring element of Forward Pricing Rate

Agreements (FPRA), Forward Pricing Rate Recommendations (FPRR), and/or

Approved Billing, if applicable. This element, however, is not scored evenly. There are more points awarded for FPRAs vs. FPRRs - and further based on time of approval (even points for expired FPRAs or expired Approved Billing Rates). It is requested that GSA reconsider this methodology and award one set of points for any current FPRA, FPRR, and/or Approved Billing Rates. This would be fair and consistent with the methodology of scoring under OASIS.

We will revisit the allocation of points for each scoring element. Accreditation section H.7 “Cost Accounting Standards”: Per 48 CR 9903.201-1, CAS is not required for Firm Fixed Price or commercial item acquisitions; both of which will be allowable under the HCATS contract vehicle per the RFP at page 5 section B.1.6

“Contract Type”. The Excel document J.7 Cost-Price Worksheet is set up to exclusively display cost-reimbursement pricing elements (direct labor, fringe, G&A, overhead, profit, etc.) and does not provide a section for offerors to display FFP labor rates. Additionally, the RFP instructs offerors that they are not allowed to modify the pricing template. How shall offerors who are exempt from having an DCAA-approved CAS system propose their FFP rates?

The labor rates awarded under HCaTS will be awarded as Fixed

Price with Economic Price Adjustment (FP EPA), to be referenced only when a sole-sourced Time-and-Materials task order is issued.

To ensure the labor rates are fair and reasonable and the Offeror is complying with its accounting system, Attachment J.7 requires of

Offerors to breakdown their cost elements that make up the fully burdened rate per labor category.

Accreditation

L.4.1, L.5.4.1: Should the offeror submit two separate documents since the requirement in L.5.4.1 is to submit an official audit report and to provide POC information and reference page and paragraph of the audit? This requirement conflicts with the Proposal Format Table. The table indicates that the page limit is limited to the audit only. If the offeror is to submit two separate documents, what naming convention should be used for the second document?

This information will be input into the Self-Scoring Sheet

(Attachments J.5.1 and J.5.2).

Accreditation

L.4.1, L.5.4.2 Should the offeror submit two separate documents since the requirement in L.5.4.2 is to submit an official audit report and to provide POC information and reference page and paragraph of the audit? This requirement conflicts with the Proposal Format Table. The table indicates that the page limit is limited to the audit only. If the offeror is to submit two separate documents, what naming convention should be used for the second document?

This information will be input into the Self-Scoring Sheet

(Attachments J.5.1 and J.5.2).

Accreditation

L.4.1 and L.5.4.3 Should the offeror submit separate documents since the requirement in L.5.4.3 is to submit an official audit report and to provide POC information and reference page and paragraph of the audit? This requirement conflicts with the Proposal Format Table. The table indicates that the page limit is limited to the audit only. If the offeror is to submit two separate documents, what naming convention should be used for the second document for the FPRA, FPRR, and Approved Billing Rates?

This information will be input into the Self-Scoring Sheet

(Attachments J.5.1 and J.5.2).

Accreditation

L.4.1, L.5.4.4 Should the offeror submit two separate documents since the requirement in L.5.4.2 is to submit an official audit report and to provide POC information and reference page and paragraph of the audit? This requirement conflicts with the Proposal Format Table. The table indicates that the page limit is limited to the audit only. If the offeror is to submit two separate documents, what naming convention should be used for the second document?

This information will be input into the Self-Scoring Sheet

(Attachments J.5.1 and J.5.2).

Accreditation

L.4.1, L.5.4.5 Should the offeror submit two separate documents since the requirement in L.5.4.5 is to submit a certification and to provide POC information and reference page and paragraph of the certification? This requirement conflicts with the

Proposal Format Table. The table indicates that the page limit is limited to the certification only. If the offeror is to submit two separate documents, what naming convention should be used for the second document?

This information will be input into the Self-Scoring Sheet

(Attachments J.5.1 and J.5.2).

Accreditation

L.4.1, L.5.4.6 Should the offeror submit two separate documents since the requirement in L.5.4.5 is to submit a certification and to provide POC information and reference page and paragraph of the certification? This requirement conflicts with the

Proposal Format Table. The table indicates that the page limit is limited to the certification only. If the offeror is to submit two separate documents, what naming convention should be used for the second document?

This information will be input into the Self-Scoring Sheet

(Attachments J.5.1 and J.5.2).

Accreditation

L.4.1, L.5.4, 7 Should the offeror submit two separate documents since the requirement in L.5.4.5 is to submit a certification and to provide POC information and reference page and paragraph of the certification? This requirement conflicts with the

Proposal Format Table. The table indicates that the page limit is limited to the certification only. If the offeror is to submit two separate documents, what naming convention should be used for the second document?

This information will be input into the Self-Scoring Sheet

(Attachments J.5.1 and J.5.2).

Accreditation

We are a current small business TMA contractor and have been performing training and human capital studies for over 17 years. We have never once needed many of the certifications called for in the solicitation (e.g., ISO, CMMI, EVS). We believe there is the danger, that having these certifications in the scoring system could skew the outcomes in unanticipated ways. For example, it may be that small business IT firms that do some human capital and training projects on the side would score higher than true training and human capital firms. We request you eliminate these certifications (or further reduce their point count).

We have removed the ISO 14001 and CMMI certifications and the

Contractor Key Personnel scoring element due to Industry

Feedback.

Accreditation

The current requirements and evaluation criteria outlined for vendors to compete on the small business vehicle significantly impact the number of qualified vendors to support this human capital requirement. Moreover, the evaluation criteria are hyper-focused on operational processes (e.g., EVM, estimating systems) rather than on the core of what the Government is interested in—quality of services to customers.

Based on the current requirements, it is questionable as to whether the Government will get the most qualified pool of small businesses. It is our recommendation that the

Government consider removing these additional process-centric evaluation criteria for the HCaTS SB vehicle and rather focus on criteria that evaluate the vendors’ ability to successfully deliver goods and services to the Government.

We have removed the ISO 14001 and CMMI certifications and the

Contractor Key Personnel scoring element due to Industry

Feedback.

C.3.3 Given that IT is considered an ancillary support service or product on HCaTS task orders, will the Government remove additional scoring points for EVMS?

Justification/Reason/Explanation: The FAR only requires the use of EVMS in major acquisitions for IT/systems development. Similarly, OPM-specific guidance requires

EVMS in major acquisitions for IT development. IT and system development/maintenance are ancillary services under HCaTS. Federal EVMS compliance accreditation is limited, by the government, to contractors supporting major programs. Contractors specializing in human capital and training solutions are unlikely to have accredited EVMS and therefore will be penalized relative to large system integrators that also happen to provide HC and TS.

Although the FAR requires the use of EVMS in major acquisitions for IT/systems development, there may be task orders issued under

HCaTS that can benefit from EVMS, especially under KSA 3.

Accreditation

L.5.4.7 ISO 14001:2004 specifies the requirements of an environmental management system (EMS). The registration/certification process is costly and can take several years. Will the government remove additional scoring points for ISO

14001:2004? Justification/Reason/Explanation: Contractors specializing in human capital and training solutions are unlikely to have accredited EMS and therefore will be penalized relative to large system integrators, manufactures and ther suppliers that also happen to provide Human Capital and Training services.

This accreditation will be removed from the RFP. Accreditation

H.6.1-3 The Department of Defense (DOD) has established business system criteria in the DOD Federal Acquisition Regulation Supplement (DFARS), see DFARS

252.242-7005. In accordance with the DFARS requirements, the adequacy of contractor business systems is determined by the cognizant Administrative

Contracting Officer (ACO). Will GSA accept DOD ACO determinations of business system adequacy in lieu of DCAA audit results?

Yes, a Cognizant Federal Agency auditing any accreditation with the exception of the Accounting System is allowed.

Accreditation

H.6.1-3 In many cases, DCAA has never audited a contractor’s accounting system. If

DCAA has never audited the contractor’s accounting system is the contractor ineligible for award under the HCATS program? Would a DCMA ACO determination of adequacy suffice in lieu of a DCAA audit?

All Offerors that are considered for award based on being in the

Top 40 proposals per Pool will have the option to have their accounting system audited by DCAA. If an Offeror has an accounting system that was audited by the DCAA within the last three years and there have been no changes, their system will not need to be audited again. Only Offerors with audited accounting systems will be able to compete for cost-reimburseable type work at the task order level.

Accreditation

H.6.4 The creation and change of FPRA, FPRR, PBR and/or Approved Billing Rates is frequently the result of negotiation with the cognizant ACO. If there is no audit report, is there a specific submission requirement for some other type of information or will a contractor explanation of the change be sufficient?

The RFP will be amended to allow for a CFA's Contracting Officer's determination as verification. It will also be amended to state that the FPRA, FPRR, and Approved Billing Rates shall bave be current and audited/determined acceptable within the last three years.

Accreditation

Does the Government have performance data that demonstrates that a company having ISO certification or a CMMI rating performs better than companies that do not have ISO certification or CMMI rating?

The CMMI Certification will be removed from the RFP. There will also be changes to the ISO accreditations that are scoring elements. These were determined based on reseach and industry feedback.

How will the Government verify that the division/organization/group within the company that submits a proposal stating that they are ISO certified are actually the division/organization/group that will be performing the work?

The Offeror shall submit enough verifiable information to substantiate the division/organization/group that is submitting the proposal is the one that has the certification. The HCaTS PMO will audit contracts and reach out to Ordering Contracting Officers to verify that the Contractor is performing in accordance with its contract.

Accreditation

What is the value of an Earned Value Management Systems in the Size Standard for small businesses under $11 million (Pool 1)?

The HCaTS PMO chose accreditations based on their value for work that may be performed and not based on size standard.

Accreditation

Will the Government consider providing credit for accreditations such as IACET, whereby Offerors have undergone a rigorous third-party review and have met the nationally-recognized standards set forth by ANSI and IACET to ensure high quality continuing education and training programs for adult learners? IACET is the premier standard-setting organization for the continuing education and training industry, and is an accredited Standards Developing Organization (SDO) by the

American National Standards Institute (ANSI). Accreditation by ANSI signifies that

IACET’s procedures meet the Institute’s essential requirements for openness, balance, consensus, and due process.

Several large, Federal training institutions are also accredited by IACET, to include, but not limited to FEMA’s Emergency Management Institute, the Defense Acquisition

University, and the Federal Deposit Insurance Corporation’s Corporate University.

This accreditation was previously under consideration and was determined not to be included in the RFP.

Accreditation

ISO 14001 was designed for manufacturers to demonstrate how they protect the environment. Given this is a services-only vehicle can the government explain why application of this standard is relevant (adds points to the evaluation) and how the government intends to apply it post award?

This accreditation has been removed from the final RFP. Accreditation

When the government requires proof of ISO certification it becomes a cost-reimbursable line item on a contract. Will the government in fact reimburse companies for this certification or consider removing/modifying the ISO requirement to state “company certifies that it follows ISO policies and procedures?

No, requiring proof of an ISO certification does not make it a cost-reimbursable line item on a contract. Offerors are eligible for additional points if they have an ISO certification, but are prohibited from passing any costs associated with obtaining or maintaining it at the contract level. Depending on the Offeror's accounting system and if the task order permits it, they may be able to pass on the cost at the task order level.

References from C.3.3., M.7: L.5.4.4; L.5.4.5; L.5.4.6; L.5.4.4.7; L.5.4.9

Discussion. C.3.3. states that, “IT is considered ancillary support service or product on task orders and may be performed and/or provided only when the service or product is integral and necessary to complete a total integrated solution under a professional service based requirement within the scope of HCaTS.” Yet, the CMMI, ISO, and EVMS requirement are so common to the Federal IT community that even small and disadvantaged set-aside IDIQs require them of the prime. Therefore, these requirements simply serve as barriers to entry for mid-to large HR/HCM companies who do not provide IT professional services. Conversely, any IT company small or large would be able to obtain substantial points for holding these certifications and accreditations regardless of their corporate investment, commitment, and experience in the HR/HCM vertical that is the purpose of HCaTS.

Suggestion. Eliminate the EVMS ANSI/EIA, CMMI, and ISO certifications and instead allow them to be included as necessary at the TO level as necessary. Since IT is ancillary to HCaTS, these certifications and accreditations will likely be irrelevant to the majority of HCaTS task orders.

The CMMI and ISO 14001 Certification will be removed from the

RFP. There will also be changes to the ISO accreditations that are scoring elements. These were determined based on reseach and industry feedback.

Accreditation

F.5 Performance Standards reads . . . . “The Contractor shall maintain throughout the ordering period of HCaTS, at a minimum, the accreditations at time of contract award.

For example, if a Contractor’s proposal included an acceptable accounting system and ISO 9001:2008 certification and made a part of contract award, then the

Contractor shall maintain an acceptable accounting system and ISO 9001:2008 certification for the duration of the HCaTS ordering period.”

However, as the industry evolves, certain certifications are replaced or superseded by new certifications. Maintaining a certification in these cases may, in fact, not be in the best interest of the government. We recommend the statement be reworded accordingly . . . “The Contractor shall maintain or exceed throughout the ordering period of HCaTS, at a minimum, the accreditations at time of contract award.”

The RFP will be amended to reflect your recommendation. Accreditation

M.7, F.5 Performance Standards reads . . . .“An acceptable accounting system is mandatory for all Contractors. Compliance with the Cost Accounting Standards (CAS) are mandatory unless covered by exemption under 48 CFR 9903.201-1 and 48 CFR

9903.201-2. All other accreditations (i.e., certifications, clearances, systems) are optional;”

We agree with the government’s approach as stated. However, we feel it is contradictory for the government to award evaluation points for optional systems and accreditations when many of these systems can’t be certified by DCAA unless the government mandates them. DCAA only approves them only on an as needed basis.

We suggest the government not award evaluation points for these optional certifications and systems.

We have removed the Contractor Key Personnel scoring element due to Industry Feedback. The final RFP will only have company-wide accreditations.

We will keep the optional organizational accreditations but will revisit the allocation of points for each scoring element.

H.6.2 – H.6.8, M.7 In Section H of the RFP, there are numerous certifications that offerors are “encouraged” to have. These include things such as an acceptable estimating and purchasing system, forward pricing rate agreements, EVMS, CMMI

Level 3, ISO 9001:2008 and 14001:2004, etc. For the most part, these certifications are not relevant to training and human capital development contracts. In fact, in our

25 year history, completing over 8,000 training and human capital task orders, these certifications/systems have never been required.

The certifications listed are far more applicable to Information Technology hardware and services contracts. Therefore, companies that hold these certifications are more likely to be systems integrators, and not companies that specialize in the work being procured under this contract vehicle. Although these certifications are not mandatory, additional evaluation points are assigned for having them. This will put companies specializing in human capital and training development at a disadvantage; this seems contrary to what OPM would want and what would be in the best interest of this contract. We suggest that GSA remove the certifications that are encouraged in

H.6.2 – H.6.8 and request that such certifications, if deemed necessary in the future, can be requested at the task order level.

We have removed the Contractor Key Personnel and ISO 14001

Certification scoring element due to Industry Feedback. The final

RFP will only have company-wide accreditations.

We will keep the optional organizational accreditations but will revisit the allocation of points for each scoring element.

Accreditation

Section H.6, Accreditations, and Section H.6.1, Acceptable Accounting System. Many small businesses, especially 8(a) businesses, have not yet undergone DCAA compliance audits of their accounting systems. Therefore, to demonstrate that a

HCaTS SB Contractor maintains an “acceptable accounting system,” how will the determination of “acceptable” status be rendered? Is it adequate for the Contractor to possess an accounting system that is listed on the HCaTS Program Management

Office (PMO) master list of acceptable accounting platforms/software systems? Or, alternatively, will each HCaTS SB Contractor be required to submit a statement self-certifying the fact their company possesses an acceptable accounting system? Is self-certification of an acceptable accounting system the purpose of the attached form

“J.3, Modified Pre-Award Survey: SF 1408”? How will the acceptability of the accounting system be validated by the PMO and/or OCO? The text in these sections is unclear.

All Offerors that are considered for award based on being in the

Top 40 proposals per Pool will have the option to have their accounting system audited by DCAA. If an Offeror has an accounting system that was audited by the DCAA within the last three years and there have been no changes, their system will not need to be audited again. Only Offerors with audited accounting systems will be able to compete for cost-reimburseable type work at the task order level.

Accreditation

Sections L.5.4.6 and L.5.4.7 (Page 127) outline scoring elements for ISO 9001:2008 and ISO 14001:2004 certifications. These certifications are heavily focused on product development and are significantly less relevant to service-oriented industries.

Specifically, these certifications are virtually never required for human capital and training tasks. Will GSA consider removing these certification from consideration?

ISO 14001:2004 will be removed from the RFP Accreditation

Systems and Certifications

We recommend that GSA reevaluate the systems and certifications included in the

DRFP to ensure that they are relevant to contract performance under the future

HCaTS vehicle. There are some included in the current draft that are not applicable to HCaTS type work, such as Earned Value Management System and ISO14001 certification for Environmental Management Systems. Rather than including them in the scoring at the master contract level and putting capable offerors that do not have these accreditations at a disadvantage, it would be more appropriate to allow agencies the option of requiring them at the task order level. Further, in order to maximize competition, systems and certifications that are necessary to the performance of the contract should be considered matters of contract administration.

They should not be evaluated subjectively for extra points during the final evaluation for award

The HCaTS Team has removed the Contractor Key Personnel scoring element due to Industry Feedback. The final RFP will only have company-wide accreditations.

In addition, ISO 14001 and the CMMI certification have been removed.

Accreditation

FPRA/FPRR/Approved billing rates—Credit is applied for Forward Pricing Rate

Agreements (FPRA), Forward Pricing Rate Recommendations (FPRR), and/or

Approved Billing, if applicable. However, these items are not scored equally. There are more points awarded for FPRAs vs. FPRRs - and further based on time of approval (for expired FPRAs or expired Approved Billing Rates). We recommend that

GSA award one set of points for any current FPRA, FPRR, and/or Approved Billing

Rates.

We have removed expired FPRAs as a scoring element. Since

FPRAs are actual agreements, as oppose to an FPRR, which are just recommendations, we believe the FPRA have additional value.

Accreditation

Comment: In sections L.5.4, the Government includes scoring elements for EVMS

ANSI/EIA Standard 748, CMMI Capability Level 3, MCCI Maturity Level I, and ISO certifications. These certifications are most commonly beneficial to and required in the Information Technology (IT) field. They are cost prohibitive for cost conscious, medium sized companies that specialize in Human Resources and Human Capital

Management (HR/HCM).

Recommendation: We recommend removal of these certifications as scoring elements as they do not reflect the potential success of a prime contractor on

HR/HCM type work.

The CMMI certification will be removed from the RFP. Accreditation

Page 127-129 of the RFP: L.5.4.1 Acceptable Estimating System, L.5.4.2 Acceptable

Purchasing System, L.5.4.3 FFRA, L.5.4.4 EVMS Will the government confirm that a small business, if tied to a large business or other entity, may NOT use the other entity’s systems as if it were their own for points?

Within a corporate structure, an Offeror may utilize resources from a parent company, affiliate, division, and/or subsidiary provided that the meaningful relationship was in place at the time the contract or task order being submitted as a Relevant Experience Project was performed. The Government shall allow an Offeror to take credit for any evaluation element, including Relevant Experience

Project(s), accreditations from a parent company, affiliate, division, and/or subsidiary as long as there is a meaningful relationship to the Offeror and commitment letters are provided to the

Government.

Affiliates are business concerns that are affiliates of each other if, directly or indirectly, either one controls or has the power to control the other, or another concern controls or has the power to control both.

Division is a separate business unit of a company representing a specific business function.

Subsidiary means an entity in which more than fifty percent (50%) of the entity is owned directly by a parent corporation; or through another subsidiary of a parent corporation.

If none of the above are met, you cannot use their resources.

Accreditation

Section H.6.2, pg 51: Acceptable Estimating System

In our experience, an estimating system is required when there is a need for a contractor to provide certified cost and pricing data as outlined in DFAR 215.408(2).

FAR 15.403-1 and DFAR 215.403-1 outline the prohibition on obtaining certified cost or pricing data. The type of services outlined in the draft RFP are normally provided as commercial services, and adequate price competition normally exists. Both are scenarios where certified cost and pricing data would not be needed. As such, it is unlikely that the majority of contracts issued under the HCaTS ID/IQ, would require the need for a contractor estimating system. Even if a contractor has an estimating system in place, it is our experience that unless that contractor possesses a significant amount of contract awards in which certified cost and pricing data was required, it is highly unlikely that their estimating system has been audited by DCAA, DCMA, or any other Cognizant Federal Agency. Awarding bonus points for this requirement disadvantages companies that mainly provide commercial services to the federal government.

Q15. Would the Government consider removing the requirements outlined in H.6.2 titled Acceptable Estimating System?

This recommendation was considered but the RFP will not be amended.

Section H.6.3, pg 51: Acceptable Purchasing System

FAR 44.3 states that a contractors purchasing system review (CPSR) only be conducted “If a contractor’s sales to the Government (excluding competitively awarded firm-fixed-price and competitively awarded fixed-price with economic price adjustment contracts and sales of commercial items pursuant to Part 12) are expected to exceed $25 million during the next 12 months”. It is our experience that the services that will be requested under this contract are normally procured as commercial services, and will be awarded through the use of firm-fixed-price contracts. Awarding bonus points for this requirement disadvantages companies that mainly provide commercial services to the federal Government, and unless you meet the requirements outlined in FAR 44.3, even if a contractor has a purchasing system that would be deemed acceptable, that contractor has no control over their purchasing system being audited under a CPSR.

Q16. Would the Government consider removing the requirements outlined in H.6.3 titled Acceptable Purchasing System?

This recommendation was considered but the RFP will not be amended.

Accreditation

For these optional systems – would the government consider accepting a third party assessment? Or would the government make enough time for offerors to go through a DCAA audit?

No, all optional accreditations shall have been received by the date the RFP closes by a Government entity.

Accreditation

Question: Can the government provide further clarification to the following requirement: The Contractor shall have and maintain an acceptable accounting system that will permit timely development of all necessary cost data in the form required by the proposed contract type. Does this require that the SB have a certified

DCAA compliant accounting system?

All Offerors that are considered for award based on being in the

Top 40 proposals per Pool will have the option to have their accounting system audited by DCAA. If an Offeror has an accounting system that was audited by the DCAA within the last three years and there have been no changes, their system will not need to be audited again. Only Offerors with audited accounting systems will be able to compete for cost-reimburseable type work at the task order level.

Accreditation

Credit for Earned Value Management Systems should be granted only at the task order level, where it is clear whether and how EVMS is relevant and of value.

Consideration should also be given to aligning any EVMS requirement to the new

DoD guidance under which the EVMS threshold will be raised to $100 million.

This recommendation was considered and the RFP will not be amended.

L.5.1.5. and H.6.1 We strongly recommend that the requirement to secure a future

DCAA audit not be a pass/fail requirement at the IDIQ level.

• The predecessor contract, TMA, successfully met agencies needs without procuring cost reimbursable contracts, and the requirement at the IDIQ level is overly restrictive for FFP and T&M Task Orders.

• It penalizes those firms whose core services directly relate to Pools 1 and 2, such as firms who performed successfully under the TMA contract and new competitors who successfully perform for many non-DoD federal agencies as well as other industry sectors but have not required a DCAA audit in the past, while inappropriately providing an advantage to those firms who perform Pool 1 and 2 services as an ancillary function, but have DCAA audits.

• Given the backlog and time to schedule and complete a DCAA audit, the business case to pursue HCaTS without confidence of being able to compete for task orders cannot be made which will result in significantly less competition for the

HCaTS vehicle and post award.

Offerors are not required to have an audited accounting system prior to award. All Offerors that are considered for award based on being in the Top 40 proposals per Pool will have the option to have their accounting system audited by DCAA. If an Offeror has an accounting system that was audited by the DCAA within the last three years and there have been no changes, their system will not need to be audited again. Only Offerors with audited accounting systems will be able to compete for cost-reimburseable type work at the task order level.

Accreditation

L.5.4.4 We recommend that the government remove the option to receive additional points for an EVMS from the RFP for the following reasons:

• EVMS is required for major acquisitions for development, according to the FAR, Subpart 34.2 and OMB Circular A-11

• With the elimination of major development work associated with the original

Pool 3 and exclusion of Learning Management Systems, the requirement for EVMS is inconsistent with the FAR applicability and beyond the scope of Pools 1 and 2

• Companies who focus on Human Capital and Training services most often would not seek or qualify for a DCMA audit of EVMS

Although the FAR requires the use of EVMS in major acquisitions for IT/systems development, there may be task orders issued under

HCaTS that can benefit from EVMS, especially under KSA 3.

Accreditation

L.5.4.5 With the elimination of the original Pool 3, we recommend modifying this section of the RFP to only include CMMI Maturity Level 3 for Services. Many Training and Human Capital consulting companies do not have CMMI in Development due to the nature of work. Allowing CMMI in Development would give an advantage to those firms who specialize in systems development.

This certification has been removed. Accreditation

Would the Government consider removing the mandate for Small Business contractors to have an accounting system audited and found acceptable by DCAA from the HCaTS SB RFP? This mandate is understood for the large business track, however, most small businesses do not have audited accounting systems.

Small businesses are not required to have an audited accounting system prior to award. All Offerors that are considered for award based on being in the Top 40 proposals per Pool will have the option to have their accounting system audited by DCAA. If an

Offeror has an accounting system that was audited by the DCAA within the last three years and there have been no changes, their system will not need to be audited again. Only Offerors with audited accounting systems will be able to compete for cost-reimburseable type work at the task order level.

1. Page 26 of 144 . . . F.5 Performance Standards reads . . . . The Contractor shall maintain throughout the ordering period of HCaTS, at a minimum, the accreditations at time of contract award. For example, if a Contractor’s proposal included an acceptable accounting system and ISO 9001:2008 certification and made a part of contract award, then the Contractor shall maintain an acceptable accounting system and ISO 9001:2008 certification for the duration of the HCaTS ordering period.

Comments/Suggestions: We recommend the statement be reworded accordingly . . .

“The Contractor shall maintain or exceed throughout the ordering period of HCaTS, at a minimum, the accreditations at time of contract award. For example, if a

Contractor’s proposal included an acceptable accounting system and ISO 9001:2008 certification and made a part of contract award, then the Contractor shall maintain an acceptable accounting system and ISO 9001:2008 certification for the duration of the

HCaTS ordering period.” As the industry evolves, certain certifications are replaced or superseded by new certifications. Maintaining a certification in these cases may not be in the best interest of the government.

The RFP will be revised to reflect equivalency for successor certifications.

Accreditation

2. Page 26 of 144 . . . F.5 Performance Standards reads . . . .“An acceptable accounting system is mandatory for all Contractors. Compliance with the Cost

Accounting Standards (CAS) are mandatory unless covered by exemption under 48

CFR 9903.201-1 and 48 CFR 9903.201-2. All other accreditations (i.e., certifications, clearances, systems) are optional;”

Comments/Suggestions: While its reasonable to request compliance with CAS, it is unreasonable for the government to award evaluation points for optional systems when many of these systems can’t be certified by DCAA unless the government requires them. In other words, they should be optional systems and the government should not award evaluation points for them.

Your recommendation will be considered. Accreditation

7. Pages 51 and 52 of 144 . . . H.6.2 Acceptable Estimating System, H.6.3

Acceptable Purchasing System, H.6.4 Forward Pricing Rate Agreements, H.6.5

Earned Value Management Systems.

Comments/Suggestions: Training and Human Capital contracts are typically procured through Firm-Fixed Price (FFP) competitive bids. Therefore, these systems and Forward Pricing Rates are not needed. DCAA is the only body approving these systems and they only approve on an as needed basis. Additionally, they don’t have the capacity to certify these systems for every government contractor.

We recommend removing any and all points associated with these certifications, as the government does not have the capacity to certify these systems.

Your recommendation will be considered. Accreditation

8. Page 53 of 144 . . . H.6.6 CMMI Level Certification

Comments/Suggestions: This certification is predominantly used in the manufacturing industry. While CMMI can be a beneficial certification to achieve, there has never been a requirement for CMMI for training and human capital services.

We recommend lowering the certification level to II.

The CMMI certification will be removed from the RFP. Accreditation

9. Page 53 of 144 . . . H.6.8 ISO 14001:2004 Certification

Comments/Suggestions: This certification is irrelevant to this procurement. We recommend removing it from the solicitation or downgrading to a minimum level.

This accredidation has been removed. Accreditation

Standard Form 1408 is labeled as 5 questions with sub-sections under each question

(e.g., 2(a)) - The solicitation states "offeror is not required to answer questions 3 through 21" - does this refer to numbers 2-5 with all subsections? Is there an SF1408 with 21 questions labeled 1-21? If so, can GSA provide a copy or a link for contractors to access?

The final version of J.3 Pre-Award Survey will reflect the correct information.

Attachments

REFERENCE: Draft Section J.10 NAICS Code Re-Determination Form; Page 1

OFFEROR COMMENT/QUESTION: Discussion: On April 3, 2015, the Government issued Section J attachments to the Draft RFP which included Section J.10 “NAICS

Code Re-Determination Form.” This Form states: “Contracting Officers: You are receiving this form because the Offeror cited in Section I claims that the majority of the work performed on the contract or task order cited in

Section II-A falls within one of the NAICS codes listed in Section II-E, and not the reported NAICS Code. The Human Capital and Training Solutions (HCaTS) team is asking that you, as duly warranted Contracting Officer of the contract or task order cited in Section II-A, certify that the scope of the contract or task order falls within one of the NAICS codes in Section II-E, and not the reported NAICS Code.” The above statement appears to be asking the Contracting Officer to make a re-determination of the appropriate NAICS code for the work performed under the cited contract; an action which is not legally permissible. By regulation, the contracting officer is required to “determine the appropriate NAICS Code and related small business size standard and include them in solicitations.” 48 C.F.R. (“FAR”) 19.303(a)(1). Thus, the required time for determining the applicable NAICS Code is at the time of solicitation, 13 C.F.R. 121.402(b), not after contract award. The NAICS code assigned to a procurement, and its corresponding size standard, is final unless timely appealed to

SBA's Office of Hearings and Appeals. FAR 19.303(c); 13 C.F.R. 121.402(d).

Question: Are you asking the Contracting Officer to make a determination to

CHANGE the NAICS from what was originally assigned?

Attachment J.10 NAICS Redetermination form will be amended in the final RFP to state that this redetermination is solely for the purposes of the evaluation of HCaTS and any redetermination will not require of the Contracting Officer to take any action or make any changes in the original contractual documents or how it was reported in PPIRS and FPDS-NG.

Attachments

J. 7 The Cost-Price Worksheet instructs “Editing or reformatting this sheet in any way is prohibited and will result in your worksheet not being reviewed”

Would the government allow the offeror to edit the Cost-Price Worksheet in order for the offeror to comply with its accounting and estimating systems?

No, the Offeror must fit their cost elements into those provided into

J.7 Cost/Price Worksheet.

Attachments

J.5.2 and Section H.6.1 states “Only those Contractors that maintain an acceptable accounting system, as approved by the HCaTS CO, shall be eligible for task order solicitations.” In addition, the Attachment J.5.2, Self Scoring Work Sheet requires contractors to state whether their accounting system has been audited. These statements may lead the reader to believe that contractors that have not been audited by DCAA may be barred from the award of task orders from this

RFP. Or it may simply mean that said contractors will need to have their systems audited before an award can be made. Could the government please clarify this requirement? Will the government request the DCAA conduct an accounting system audit for those contractors that are not currently approved at the time of the proposal? Will the government provide contractors the time to go through this process with DCAA without penalty or discrimination?

All Offerors eligible and considered for award will have the option to have their accounting system audited by DCAA. Only Offerors with audited accounting systems will be able to compete for cost-reimburseable type work at the task order level.

Attachments

L.5.1.2 Attachment J.2 (Proposal Checklist) seems to be missing from the posted attachments. Can you please provide Attachment J.2 for Offerors to review?

The Final RFP will have this attachment included. Attachments

J.5.2 and L.5.2.1 Column F does not calculate beyond row 16. Instructions to offerors on page 120 state that the sheet should auto-sum. Will the Government please provide an updated copy of Attachment J.5.2 Self Scoring Worksheet SB Pool 2 in which the auto-sum calculations are included?

The Self Scoring Worksheets (Attachments J.5.1 and J.5.2) were released in draft form and will be fully functioning when released with the RFP.

Attachments

L.5.2 This section states that “Additional instructions for filling out Relevant

Experience Projects Template is found in Section J.5.3 (Self Scoring Worksheet SB

(Sample)).” Attachment J.5.3 seems to be missing. Can you please provide

Attachment J.5.3 for Offerors to review?

This will be released with the RFP. Attachments

Attachment J7 states that “DCAA audited rates should be input” however the solicitation does not indicate that a DCAA audit is required prior to submission. Will the government clarify or remove the requirement for DCAA audit prior to submission?

All Offerors that are considered for award based on being in the

Top 40 proposals per Pool will have the option to have their accounting system audited by DCAA. If an Offeror has an accounting system that was audited by the DCAA within the last three years and there have been no changes, their system will not need to be audited again. Only Offerors with audited accounting systems will be able to compete for cost-reimburseable type work at the task order level.

Attachments

Recommendation 4: Eliminate Estimating the Total Value of a KSA within J.5.1 and

J.5.2 Scoring Sheets

Within Attachments J.5.1 and J.5.2 there is a requirement to specify the total dollar value of the KSA and the total percentage associated with a KSA.