H92401-25-R-0002_Final_RFP_QNA_Round_1_25_MAR_25.pdf

ITEM #

SECTION

NUMBER

NAME OF SECTION

COMMENT TYPE

(Select from drop down)

SOURCE SELECTION

SENSITIVE OR

PROPRIETARY

INFORMATION IN

QUESTIONS / COMMENTS?

(Yes/No)

QUESTIONS / COMMENTS

(With justification of why considered source selection sensitive if applicable) Government Answer

1 L Instructions, Conditions and Notices to Bidders

Critical No

L.0.4; M.5: The Government states that it intends to reserve one award for small business. On most multiple award contract acquisitions where there are both large and small business awards, the solicitation includes a different set of criteria for small business offerors to meet compared with those of large businesses, particularly in the areas of past performance or corporate experience since small businesses by nature don't have the same breadth or magnitude of experience.

In order to expand competition, will the Government considering establishing modified proposal requirements and evaluation criteria that apply only to small business offerors to allow for more small businesses to compete?

No. This is the third round of TREX with the same criteria for both large and small businesses. It has been proven to be very successful for small businesses given the fact that all three companies that are current TREX primes were all small businesses when they won an award in 2020.

2 L Instructions, Conditions and Notices to Bidders

Critical No

L.2.1.4.1: The past performance requirements, as currently listed, make it very difficult for a small business, especially an SDVOSB, to provide multiple different contracts that must each meet all of the stated requirements for scope, complexity, and magnitude. However, it is reasonable to expect a small business to be able to deliver the totality of those requirements across a combination of contracts.

Will the Government consider revising the RFP for small business offerors to add "The totality of past performance citations, considered together, must meet the stated requirements."?

Since this question also came up during the Draft RFP phase, a more in-depth response is being provided. The Government does not consider the consolidation of several efforts in order to demonstrate relevant past performance is relevant to TREX. Additionally, we believe that approach is also inconsistent with the requirements outlined in the mandatory DoD Source Selection Guide (available online). The definition of relevance as outlined in the RFP and the Guide is "Present/past performance effort involved similar scope and magnitude of effort and complexities this solicitation requires."

Further the Guide states in part; "3.1.3.1. There are three aspects to the past performance evaluation: recency, relevancy (including context of data), and quality (including general trends in contractor performance and source of information). All three aspects must be considered for each of the contracts or requirements evaluated."

It goes on to state "3.1.3.1.2. Relevance. The second aspect is to determine how relevant a recent effort accomplished by the offeror is to the effort to be acquired through the source selection...In establishing what is relevant for the acquisition, consideration should be given to those aspects of an offeror’s history of contract (or subcontract) performance that would provide the most context and give the greatest ability to measure whether the offeror will successfully satisfy the current requirement. Common aspects of relevancy include, but are not limited to: similarity of product/service/support, complexity, dollar value, contract type, use of key personnel (for services), and extent of subcontracting/teaming...With respect to relevancy, more relevant past performance will typically be a stronger predictor of future success and have more influence on the past performance confidence assessment than past performance of lesser relevance."

Further, as outlined in Section M.2, the Government will only assess performance (mainly via CPARs) for those recent and relevant efforts. While the Government will assign an Acceptable or Unacceptable rating for Factor 2 considering the offeror’s team’s overall recent/relevant performance record and use a holistic approach to determine the Government’s expectation of the offeror’s team’s (including both the prime and major subcontractors) ability to successfully perform the required effort, (as also stated in Section M.2), the relevancy determination must be made based on each standalone effort.

Due to the RFP only including relevant or not relevant criteria (vs. somewhat, very, etc.) it is even more important that the criteria used is relevant to the scope of TREX. Proposing on 30 RFPs across all and/or several company contracts is vastly different than proposing on potentially 51-77 annually on just one IDIQ as projected under TREX. (NOTE: post final RFP projections were higher at 75-90).

Regardless, setting the bar lower to 30 (roughly 50% lower) was determined to be reasonable in the Government's opinion.

3 L Instructions, Conditions and Notices to Bidders

Critical No

L.2.1.4.1:The complexity requirement that a bidder have an IDIQ contract on which they have delivered 30+ competitive DO/TOs severely limits competition and prevents most small businesses from responding to this solicitation. If a company wins a competitive single award IDIQ with multiple DO/TOs, it is still required to successfully structure, price, and deliver a reasonable, realistic, and executable offer to the Government's satisfaction, even though each DO may not be competitive — requiring the same processes to be in place as if each of those DO/TOs was competitive.

In the case of a single award IDIQ awarded based on a competitive acquisition, do the various subsequent TO/DOs satisfy the past performance criteria for complexity? If so, recommend the Government revise the RFP to state "Complexity: required a Secret Facility Clearance or higher, included subcontracting requirements with multiple OEMs, vendors, and/or suppliers; and required multiple DO/TOs awarded as a result of a competitively awarded contract vehicle (minimum of 30 submissions annually)."

No, the Government does not consider non-competitive DO proposals relevant to TREX. Reference response to item #1. Additionally, while they could demonstrate the ability to submit higher volumes of proposals, there is a significant difference in competitive vs. non-competitive proposals. In the single award construct, the follow-on DO/TOs typically do not require technical proposals (unless it is a one-off ECP type DO), the scope of the DOs are known, do not consider past performance (Ref RFP Section H.10.3), and most items are normally pre-priced and were evaluated during the base IDIQ competition. Thus it is certainly less challenging to put together a non-competitive proposal as compared to competing on new requirements (both Technical and Price) for each DO.

H92401-25-R-0002_Final_RFP_QNA_Round_1_25_MAR_25

4 L Instructions, Conditions and Notices to Bidders

Critical No

L.5.3: It is not possible for companies to formally request or undergo a DCMA audit of a purchasing system without clear justification arising from a contractual requirement. Therefore, until an award requiring a DCMA audit is received, there are no grounds for a company to request one with any chance of DCMA agreeing to perform it. From our one-on-one Industry Day meeting for this competition, we understood that a bidder would be considered acceptable as long as they had the systems in place to pass a potential audit.

For small business offerors without the previous opportunity for a DCMA purchasing system audit, would the Government consider adjusting this requirement to allow small business offerors to also submit their purchasing system justification similarly to the delayed audit offerors in lieu of a DCMA approval?

If so, would the Government revise the RFP to state: "If the offeror does not have documentation from DCMA, DCAA, or other CFA approving its accounting system and/or purchasing system due to lack of previous justification, the offeror must demonstrate that it has the processes in place to request such an approval upon award."?

That is correct. The RFP does allow for offerors to submit information showing that they are capable of being deemed acceptable if they do not currently have systems deemed acceptable by DCMA. RFP Section L.5.3 "The offeror shall provide documentation from DCMA, DCAA, or other Cognizant Federal Agency (CFA) that allows the Contracting Officer to determine that the contractor’s accounting and purchasing systems as defined in DFARS clause 252.242-7005 are acceptable or are capable of being deemed acceptable as defined in 252.242-7006 and 252.244-7001 respectively. If the offeror does not have documentation from DCMA, DCAA or other CFA approving its accounting system and/or purchasing system due to Government caused delay, the offeror must provide evidence that approval was requested and describe how the business system(s) are acceptable as defined in each of the applicable business system clauses."

However, to avoid confusion, an Amendment will be issued to further clarify Section L.5.3 as follows (updated verbiage is highlighted in bold text):

"L.5.3 The offeror shall provide documentation from DCMA, DCAA, or other Cognizant Federal Agency (CFA) that allows the Contracting Officer to determine that the contractor’s accounting and purchasing systems as defined in DFARS clause 252.242-7005 are acceptable or are capable of being deemed acceptable as defined in 252.242-7006 and 252.244-7001 respectively. If the offeror does not have documentation from DCMA, DCAA or other CFA approving its accounting system and/or purchasing system due to Government caused delay and/or not previously meeting the threshold requirements for a Contractor Purchasing System Review (CPSR) IAW FAR

44.302 and DFARS 244.302 , the offeror must provide the following. For the Accounting System review; evidence that approval was requested and describe how the system is acceptable as defined in 252.242-7006 (c). For the CPSR review; either a) evidence that approval was requested or b) a confirmation statement that they do not meet the threshold requirements IAW FAR 44.302 and DFARS 244.302 for a CPSR and describe how the system is acceptable as defined in 252.244-7001 (c)."