Questions and Answers Virtual Industry Day Posting.docx

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NAVSUP Virtual Industry Day - NETSAFA International Training Center
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N0018926VID001
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This is a Questions and Answers document from a Virtual Industry Day for the NETSAFA International Training Center (NITC) task order opportunity, posted on 16 September 2026. The document captures 61 detailed questions raised by industry during and after the 6 August 2026 virtual industry day, along with Government responses addressing critical clarifications on contract structure, invoicing, personnel, security, and operational requirements.

The Q&A addresses fundamental contracting issues including: (1) Funding and task order structure under SeaPort NxG as a cost-plus-fixed-fee completion-type effort with incremental funding through modifications, with ROMs forming the basis for estimated costs; (2) Payment terms and invoicing procedures, confirming FAR 52.232-25 Alternate I with Net 30 payment terms, cost voucher document type, and COR review within 24 hours of PIEE submission; (3) Contract administration data placement in Section G rather than the PWS, including DFARS clauses, routing tables, and billing instructions; (4) Personnel qualifications and staffing structure with NTE FTE caps by labor category, including Program Manager, Curriculum Manager, instructors, System Administrator, and support positions, with acknowledgment that surge mechanisms and continued development funding must be addressed; (5) Security requirements clarification, noting the Government will review whether Tier 3 investigations and DD Form 254 requirements are appropriate for unclassified work; (6) Invoicing complexities including per-student cost allocation, handling of course cancellations and no-shows, 100 percent AQL standards, and recovery of retained personnel costs between funded requirements; and (7) Operational details regarding historical utilization data collection, travel and ODC parameters, curriculum maintenance versus development scope, transition planning with a 30-45 day phase-in period at no cost to the Government, and clarification that the Kuwait Country Liaison Office administrative support is out of scope though instructional support for Kuwaiti students remains in scope. The Government indicates that many unresolved issues and placeholder values in the draft PWS will be clarified and filled in within the forthcoming formal solicitation, which is anticipated to be released as an unrestricted, full-and-open competitive SeaPort NxG task order with a base period plus four option years and an additional six-month FAR 52.217-8 option, all separately priced.

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Questions & Answers – NETSAFA NITC

No.
Section
PWS / Reference
Topic
Question
Government Response
Funding/Invoicing
Are task orders awarded on contractor developed ROMs?
ROMs are used to form the basis of an estimated cost for a particular course. A modification is then issued to the base task order obligating incremental funding for the course. Only one Task order is issued and funding is for specific courses is applied via modification.
2
A
SeaPort NxG Basic Contract / FAR 16.505
Order of Precedence and Conformance with the Basic MAC
Task orders under SeaPort NxG are issued by a Task Order Contracting Officer at an authorized ordering activity and, under Section C.8.1 of the basic contract, are accepted and performed within the scope of that agreement. The terms and conditions of the basic Multiple Award Contract, administered by the procuring contracting officer at NAVSEA, are not modified by a task order Performance Work Statement. Several provisions in the draft PWS establish terms and conditions rather than describe work to be performed, including payment terms, invoice document type, and payment instructions. Please confirm: (a) the order of precedence that will apply to the resulting task order, and that the basic contract governs where a conflict exists between the basic contract and the task order PWS; (b) that terms and conditions will be set forth in the task order Sections B through I and the accompanying Terms and Conditions document rather than in the PWS; and (c) where the draft PWS establishes a term that differs from the basic contract, whether that difference is intentional and has been coordinated with the procuring contracting officer for the basic contract, or whether the PWS will be conformed to the basic contract prior to release of the solicitation.
The Provided draft PWS will be reviewed to ensure compliance with the terms of the ordering instrument used.
3
A
Announcement / Section B
CPFF Form and Fee Structure
The announcement identifies a cost-plus fixed-fee task order, while the PWS establishes not-to-exceed (NTE) full-time equivalent (FTE) hour caps by labor category and directs that each Rough Order of Magnitude (ROM) be priced and invoiced by course, date, and country. Please confirm whether the task order will be CPFF term (level of effort, FAR 16.306(d)(2)) or CPFF completion, and describe how fixed fee will be established and earned. Under a term form, please confirm how fee is adjusted when the Government reduces or cancels a planned level of effort. Please also confirm the maximum fee percentage and the maximum contractor pass-through rate established by the basic contract that will apply to this order.
The task order is anticipated to be awarded as a CPFF completion type effort. The total fixed fee may be reduced proportional to the work completed on a contracted course prior to its completion. No costs or fee will be paid for a course that is ‘planned’ but not contracted for and for which no funding has therefore been obligated. Maximum fixed fee percentages are established in the FAR. While there are no numerical maximum percentages on pass-through charges, the FAR prohibits excessive pass-through charges where the contractor provides little to no added value.
4
A
Invoicing – Payment Terms
Net 45 Payment Terms Are Not Authorized
The PWS states payment terms of Net 45 days. FAR 32.903 and the prescription at FAR 52.232-25 permit an agency to insert a period shorter than 30 days; they do not authorize a period longer than 30 days. For a cost-reimbursement contract for services, FAR 32.908(c) directs use of FAR 52.232-25 Alternate I, under which interim payments are invoice payments due on the 30th day after receipt of a proper invoice and subject to Prompt Payment Act interest. Please confirm that (a) FAR 52.232-25 Alternate I will be included, and (b) the blank at FAR 52.216-7(a)(3) will be completed as the 30th day.
Concfirming inclusion of FAR 52.232-25 Alternate I, and the blank at FAR 52.216-7(a)(3) will be completed as the 30th day.
5
A
Invoicing – Routing
COR Pre-Review Creates an Unbounded Gap Ahead of the Payment Clock
The PWS requires invoices to be e-mailed to the COR for review and approval before submission in PIEE. Because the Prompt Payment clock does not start until a proper payment request is received by the designated billing office through PIEE, any COR review conducted outside PIEE is time the contractor finances with no corresponding Government obligation and no visibility to DFAS. Please clarify: (a) will COR review instead occur inside PIEE in the Acceptor or Approver role, where it is time-stamped and auditable; (b) if an out-of-system pre-review is retained, what is the maximum COR review period; and (c) will the Government confirm that a contractor may submit into PIEE if the stated review period lapses without response, so that the payment clock is not indefinitely deferred?
Concur, the requirement will be changed to submitted to the COR within 24 hours of submission to PIEE. The COR will notify DFAS if there are any irregularities which will result in a rejected invoice
6
A
Invoicing – Document Type
Invoice 2-in-1 Is Not Permitted on Cost-Type Line Items
The PWS directs submission via PIEE as an Invoice 2-in-1. DFARS 252.232-7006(f)(1)(i) states that for cost-type line items, including labor-hour and time-and-materials, the contractor shall submit a cost voucher. Invoice 2-in-1 is available only for fixed-price line items for services. Please confirm the document type for this CPFF task order will be Cost Voucher, and confirm whether DCAA will act as auditor in the WAWF workflow, since that step affects the payment timeline under FAR 52.216-7(a)(3).
Invoice type and process will be determined by contract type and WAWF routing table.
7
A
Invoicing – Contract Placement
Invoicing Requirements Must Appear in Section G, Not the PWS
The detailed invoice content, CLIN/SLIN/ACRN mapping, and document-type direction currently reside in the PWS. DFAS and the designated payment office are not parties to the PWS and process payment requests against Section G and the applicable payment clauses. Please confirm the solicitation will place these requirements in Section G, Contract Administration Data, including: (a) the DFARS PGI 204.7108 payment instruction table; (b) DFARS 252.232-7006 with a completed Routing Data Table (Issue By, Admin, Inspect By, Service Acceptor, Service Approver, LPO, and Pay Official DoDAACs); and (c) DFARS 252.204-7006, Billing Instructions�Cost Vouchers, which DFARS 204.7109(b) prescribes when a cost-reimbursement contract is contemplated.
This information will be placed in Contract Administration Data of the Solicitation and the prospective award. Clauses will be added and filled in as appropriate.
8
A
Industry Day Slide 16
Payment Instruction 'Other' Requires a Written Agreement with the Payment Office
The PWS and industry day reference PGI Clause 12, which corresponds to the 'Other' payment instruction at DFARS PGI 204.7108(d)(12). DoD Financial Management Regulation, Volume 10, Chapter 10 provides that before an alternate allocation methodology may be used, the contracting officer must negotiate a written agreement with the payment office and retain a copy in both the contract file and the payment office file. Please confirm whether that written agreement with DFAS has been executed. Given that this task order is funded by Foreign Military Sales (FMS) and Foreign Military Financing (FMF), we ask the Government to consider whether the standard FMS Allocation payment instruction better fits the requirement than 'Other.'
These requirements are no longer applicable and the task order will include the payment instructions specified at PGI 204.202-77, Table 204-1. Note the change in citation from 204.7108 due to the Revolutionary FAR Overhaul (RFO).
9
A
Industry Day Slide 16
Informational SLINs Are Not Separately Payable
Industry day guidance stated that modifications will be funded at the informational sub-line item number (SLIN) level and that invoices must be submitted at that same level. Under DFARS 204.7104-1, informational SLINs are not separately priced and are not separately identified for payment; only separately priced sub-CLINs are payable line items. Please confirm whether the sub-line items will be established as separately priced sub-CLINs or as informational SLINs, and if informational, confirm that payment requests will be submitted at the CLIN level with ACRN-level detail carried in the supporting ROM breakout.
The award resulting from this opportunity will be structured with priced SLINs under informational CLIN structure.
10
A
Industry Day Slide 19–20
Accounting Structure Complexity and FMS Long Line of Accounting
The billing scenario presented at industry day generated three sub-CLINs and four ACRNs per CLIN for a single five-week course with ten students. Scaled across the full course catalog this produces a very large number of concurrently open accounting lines. Please confirm (a) the estimated number of ACRNs the Government anticipates carrying at any one time, (b) whether the FMS long line of accounting, including country code, implementing agency, country code designator, and case line number, will be provided in the modification for each ACRN, and (c) whether the Government would consider consolidating recurring management, administrative, and CLO support into annual CLINs to reduce accounting lines.
(a) the number of ACRNS is based on IP demand and cannot be accurately estimated. (b) LOA data will be provided according to procurement system guidelines. (c) The Government welcomes input from industry on efficiency opportunities. When specifically addressing recurring management, IT, Curriculum Update, and administrative requirements; these requirements are spread across all ROMs and must be charged individually as there is not a central pool of funds that can cover these expenses as seen in traditional OM&N funded activities. As for CLO support, this requirement is expected to continue to be processed on a separate annual ROM for each IP office, i.e. RSNF and RSAF, and location.
11
A
Invoicing / FAR 52.232-20 and 52.232-22
Limitation of Cost and Limitation of Funds Application Level
On a cost-reimbursement instrument, the contractor must monitor and provide advance notification of cost overruns under FAR 52.232-20 or 52.232-22. Please confirm whether Limitation of Cost or Limitation of Funds will be applied and monitored at the task order level or separately at each ROM, SLIN, or ACRN. Application at the individual ROM level would require dozens of simultaneous 75 percent notifications and should be addressed explicitly in Section G rather than left to interpretation.
FAR 52.232-22, Limitation of Funds, will be included in the solicitation and task order award as we anticipate the award to be incrementally funded throughout performance. Funds will be obligated via SLINS for total obligation value tracking.
12
A
ROM Process / FAR 52.232-20 and 52.232-22
ROM Estimate as a Funding Ceiling on a Cost-Reimbursement Instrument
Industry day directed that ROMs be as accurate as possible with no fluff included and that contingencies be discussed before pricing, and the PWS requires the priced ROM within 48 hours. The resulting estimate is then obligated by the Government, apparently at the amount the contractor estimated. The Government describes ROMs and the annual schedule as non-binding, but that characterization addresses the Government's obligation to order; it does not address the contractor's exposure to its own estimate once that estimate is obligated as the funding line for the work. If a 48-hour estimate prepared without contingency becomes the ceiling, the contractor bears the estimating risk, which is inconsistent with a cost-plus-fixed-fee instrument under which the Government bears cost risk. Please confirm: (a) whether the amount obligated for each requirement is a funding ceiling for purposes of FAR 52.232-20 or 52.232-22, or an estimate against which allowable costs are reimbursed; (b) if a ceiling, the process and expected timeline for incremental funding increases following contractor notification under the applicable limitation clause, and whether the contractor is expected to continue performance pending that action; (c) whether the Government will accept a stated estimating range or contingency in ROMs, given that the contractor is directed to estimate within 48 hours without contingency and is then held to the result; and (d) how variances between provisional billing rates and final negotiated indirect rates will be settled where funding is distributed across a large number of separately obligated requirements, some of which may be closed before final rates are established.
The forthcoming solicitation will be clear on its face.
13
A
Various Training / FAR 52.243-2 and 52.249-6
Deobligation of Funds for Work Already Performed
Courses are cancelled and students fail to report after a modification has obligated funds and after the contractor has begun performance, including instructor preparation, curriculum readiness, and in some cases committed travel. The resulting funding action has reached the contractor as a bilateral modification deobligating those funds, without advance notice, after the costs were incurred. Because the modification is bilateral, the contractor's execution may be construed as agreement to the deobligation and as a release of the associated claim, notwithstanding that the contractor has no practical alternative to signing if it is to receive subsequent funding actions. On a cost-reimbursement instrument, cancellation of authorized work after performance has begun is a change under FAR 52.243-2 or a partial termination for convenience under FAR 52.249-6, either of which entitles the contractor to costs incurred and, in the case of termination, settlement expenses. It is not a basis to withdraw funds against which allowable costs have already been properly incurred under authorized work. Please confirm for the resulting task order: (a) the advance notice the Government will provide before a funded requirement is cancelled or reduced; (b) that funds will not be deobligated below allowable costs incurred as of the effective date of cancellation; (c) whether cancellation will be processed as a change, a partial termination for convenience, or another mechanism, and the corresponding contractor entitlement under each; and (d) that deobligating modifications will not contain release or accord-and-satisfaction language, or in the alternative that the Government will accept a contractor reservation of rights for incurred costs without treating that reservation as a failure to execute the modification.
(a) The Government will notify the contractor of cancellation of a course as soon as practicable but courses may be cancelled by the requesting country with short notice or little notice, including after the course is scheduled to begin. (b) Obligation/deobligation of funds is an administrative function and is within the Government’s discretion when required. (c) The Government will determine and pursue appropriate contractual actions on a case-by-case basis. (d) Deobligation modifications, if any, will be executed in accordance with applicable law and regulation listed in the RFO.
14
A
Industry Day Slide 19–20
Per-Student Cost Allocation and Student No-Shows
The billing model presented at industry day divides total burdened course cost by the number of enrolled students and allocates the result across country-specific ACRNs. Instructional cost, however, is substantially fixed once a course convenes: the same instructors deliver the same hours of the same curriculum whether or not the projected number of students report. When students fail to report, arrive late, or are withdrawn after convening, the per-student allocation leaves properly incurred cost with no funding line against which it can be billed, because each partner nation's case funds only its own students and no line absorbs the shortfall. Please clarify: (a) how the contractor recovers cost when actual attendance falls below the enrollment on which the ROM was priced; (b) whether the Government will establish a convening threshold at which a course is funded on a course basis rather than a per-student basis; and (c) whether a CLIN or ACRN will be established to absorb fixed instructional cost that cannot be attributed to an individual partner nation.
The forthcoming solicitation will be clear on its face.
15
A
QASP
Invoice Rejection Treatment and 100 Percent AQL
The QASP sets a 100 percent Acceptable Quality Level for invoice accuracy across a large number of ACRNs while the Government prescribes the invoice structure. If one ACRN line contains a discrepancy, will the Government reject only the affected line and pay undisputed amounts, or reject the entire payment request? Line-level resolution avoids compounding delay. Please also confirm that a rejection caused by Government-provided accounting data, a funding document error, or a payment instruction that the payment office will not process will not be counted against the contractor's AQL or recorded in CPARS.
An official QASP will be provided in the forthcoming solicitation
16
B
Deliverable Product / Deliverable Table
Absence of CDRLs and Data Item Descriptions
The Deliverable Table lists reports by name and periodicity but the draft contains no DD Form 1423-1 Contract Data Requirements Lists (CDRLs) and no Data Item Descriptions (DIDs). Without CDRLs and DIDs there is no defined format or content, no Government review and acceptance period, no resubmission process, no distribution statement, and no basis for objectively measuring the QASP timeliness and quality standards. Please confirm whether CDRLs and DIDs will be issued as Section J attachments in the solicitation. If so, may they be released in draft so offerors can estimate the associated level of effort, which materially affects the Curriculum Manager and administrative staffing.
CDRLs will be included in the forthcoming solicitation.
17
B
Deliverable Product
COR Authority to Amend Deliverables at No Cost
The PWS states that the Government reserves the right to amend the deliverables at any time and that all no-cost changes to deliverables will be decided on by the COR. This conflicts with the PWS's own statement that the Contracting Officer is the only person who can obligate the Government, and with FAR 43.102, under which only a contracting officer may execute contract modifications. It also presumes in advance that a change carries no cost. Please revise to confirm that changes to deliverables will be made by the Contracting Officer through a modification, with cost impact determined at the time of the change rather than predetermined.
Authorized changes may only be made by an appropriate Contracting Officer. The cost of any changes will be determined on a case-by-case basis.
18
B
General
Identification of the COR and ACOR
The PWS assigns extensive approval authority to the COR and ACOR, including access approval, ODC and travel approval, curriculum approval, closure determinations, instructor certification acceptance, and invoice pre-review, but does not name these individuals. Please provide the names and organizational positions of the COR, ACOR, and COR Supervisor, and confirm that appointment letters stating the limits of their authority will be issued at award and furnished to the contractor.
This information will be provided at award.
19
B
PWS Throughout
Unresolved Placeholders
The draft contains unresolved placeholders throughout, including 'Section XX' in every row of the Deliverable Table, 'PWS Paragraph XX' in every row of the QASP, 'Section XXX' in the overtime and personnel qualification cross-references, and '$XX.XX' in the Travel and ODC NTE tables. Offerors cannot map deliverables to requirements, cannot verify QASP traceability, and cannot assess travel and ODC exposure. Please confirm all cross-references will be resolved and that the Travel and ODC NTE values will be published in the solicitation prior to the due date for quotes.
The forthcoming solicitation will fill in placeholders/blanks as necessary.
20
B
Curriculum Maintenance and Development
Data Rights in Contractor-Developed Courseware
The PWS requires development of programs of instruction, interactive courseware, computer-based training, test banks, and multimedia in accordance with NAVEDTRA M-142, yet no data rights clauses are referenced. Please confirm which data rights provisions will apply to contractor-developed and contractor-modified curriculum, and confirm the delivery format and repository for developed courseware at the end of performance.
The Government’s requirements are still under development. Applicable clauses will be included in the forthcoming solicitation.
21
C
Personnel Qualifications / Contract Requirements
NTE FTE Caps Cannot Coexist with Surge and 100 Percent Manning
Each labor category carries a hard NTE FTE cap. The same PWS reserves the Government's right to exceed student-to-instructor ratios, requires the capability to provide qualified instructors on short notice, requires the capability to provide qualified instructors to ensure 100 percent manning of all courses, and industry day described surges in partner-nation throughput. These requirements cannot all be satisfied as written. Please establish a surge mechanism, such as a separately funded surge CLIN or pre-priced surge labor, define the minimum Government notification period for a directed increase in throughput, and state the procedure for exceeding an NTE FTE ceiling.
This will be addressed in the solicitation.
22
C
Deliverable Table – Staffing Report
Vacancy Contract Discrepancy Report Versus Government-Controlled Vetting
One cell of the Deliverable Table states that positions vacant longer than 30 days may result in a Contract Discrepancy Report and, in the immediately following sentence, that the contractor must ensure new staff do not report to NETSAFA until properly vetted and approved by the COR. The Security section further provides that the Command Security Manager cannot grant Tier 3 interim access, that access must come from the DCSA Vetting Risk Operations Center, and that denial or delay of access in no way relieves the contractor of the requirement to perform. Tier 3 investigation, adjudication, MP ICAM enrollment, and CAC issuance routinely exceed 30 days and are entirely Government-controlled. As addressed in Section D, the absence of a DD Form 254 means an offeror cannot compliantly initiate a Tier 3 investigation for a new hire at all, so the vacancy standard is unachievable as drafted. Please confirm that the 30-day vacancy clock is tolled from the date a qualified candidate package is submitted until the Government completes vetting and grants access, and that Government-side processing time will not form the basis of a Contract Discrepancy Report or an adverse CPARS entry.
This will be reviewed and updated, if required, in the solicitation.
23
C
Various Training / ROM Process
Carrying Cost of Cleared Staff Between Funded Requirements
ROMs and the annual schedule are non-binding, no work is authorized before a modification or written Authorization to Proceed, and modifications are anticipated every 30 to 45 days. A vetted, CAC-holding, course-certified instructor cannot be recruited, investigated, and certified within that window, so the workforce must be retained between funded events. Please clarify the intended mechanism for recovering the cost of retained personnel between ROMs, for example annually funded CLINs for core positions or a minimum guaranteed level of effort. Absent an identified mechanism, every offeror must embed retention risk in its cost proposal.
The Government will reimburse allowable costs, but the contractor may not exceed allocated funding. It is ultimately the contractor’s responsibility to provide and/or maintain adequate staffing.
24
C
Various Training / ROM Process
Repeated Pricing Events and the Absence of an Authorizing Instrument
Offerors price this requirement once to win the task order, submitting labor categories, rates, indirect rates, and fee. Thereafter the contractor prices individual requirements again through the ROM process, course by course, date by date, and country by country. Across a three-and-one-half year period of performance spanning more than twenty courses, multiple partner nations, recurring convenings, and Mobile Training Teams, this could reasonably exceed one hundred separate pricing actions, each requiring labor category mapping, FTE and hour build-up, ODCs, travel, and fully burdened cost, and each prepared within 48 hours. The PWS identifies no instrument, executed by both parties, that authorizes an individual requirement and fixes its scope. As drafted, the sequence is a Government ROM request, a contractor estimate, and a Government modification citing a dollar amount and accounting data. No document records the parties' agreement on the scope of the specific event. Please clarify: (a) what instrument authorizes each individual training requirement and defines its scope, and whether the Government will employ a bilateral task assignment, technical instruction, or comparable document as is customary on other Navy vehicles; (b) if the modification is the sole instrument, what governs when the delivered event differs from the assumptions on which the ROM was priced, including duration, student count, instructor mix, or location; (c) the number of ROM actions the Government anticipates annually, so offerors can size the estimating and program control function; and (d) where the labor to prepare recurring ROMs is funded, given that the Program Manager and administrative labor categories are subject to NTE ceilings. Can further requests the ROM response period be revised to 48 hours for acknowledgment and clarification, with five business days for the priced submission, since 48 hours is not compatible with responsible estimating on travel-intensive requirements?
The forthcoming solicitation will be clear on its face.
25
C
Industry Day Slide 16
Allocation of Management and Administrative Positions
Industry day stated that management and administrative positions impacting all ROMs must be accurately accounted for, and separately that Country Liaison Office administrative support and aviation training are placed on contract annually. Please identify which positions, specifically the Project Manager, Curriculum Manager, the three division leads, System Administrator, Logistics Specialist, Office and Administrative Support Workers, and Driver, will be funded as annual CLINs, and which are to be allocated across individual ROMs. Allocating cross-cutting labor across many ACRNs conflicts with the 100 percent invoice accuracy standard and is difficult to reconcile with cost-reimbursement vouchering.
The efforts of the PM, CM, Sys Admin, admin support, not including CLO admin, impact all students and shall be allocated across each ROM. Division leads will be charged across all ROMs for that division. Logistics and Driver will be charged to ROMs that utilize these services as indicated.
26
C
Personnel Qualifications / QASP
Mandated Costs Directed as Non-Billable
The PWS requires annual American Red Cross CPR recertification and states that CPR training and certification shall not be direct billed to the Government. High-risk training instructors must also complete medical screening every three years, psychological evaluation, and drug screening on Government request, all at no additional cost to the Government. On a cost-reimbursement contract, these are allowable costs of performing directed work under FAR Part 31. Please clarify whether the intent is that these costs be recovered as indirect costs rather than direct costs, or whether the Government intends them to be unrecoverable.
The forthcoming solicitation will be clear on its face.
27
C
General / Personnel Qualifications
Unfunded Instructor Preparation and Evaluation Time
The PWS requires that an instructor who has not taught an assigned course within the past three years complete the instructional curriculum in preparation, and requires formal evaluations of every instructor within 60 days of hire and at least every six months thereafter, all performed by a division lead or the Project Manager. Division leads are capped at one FTE each and are also required to instruct as needed. Please confirm that preparation and evaluation hours are billable within the NTE ceilings, and confirm the Government's estimate of the annual hours these activities consume so all offerors size them consistently.
This will be reviewed and updated, if required, in the forthcoming solicitation.
28
D
Security / Deliverable Product
No DD Form 254 Exists to Support the Tier 3 Requirement
The PWS states that all course material under this task order is unclassified and that classified instruction will not occur. It nonetheless requires a Tier 3 investigation for every contractor employee, and provides that interim access cannot be granted by the Command Security Manager and must instead be obtained from the DCSA Vetting Risk Operations Center (VROC). The draft contains no DD Form 254, no reference to FAR 52.204-2, and no facility clearance or safeguarding requirement. These provisions cannot be reconciled. Tier 3 is the investigative tier for Secret national security eligibility, and VROC is the DCSA element that processes national security eligibility for industry. Under FAR 4.403 and DFARS 204.404-70, a DD Form 254 is required for any contract involving contractor access to classified information, and DCSA guidance for initiating industry personnel security clearances in DISS requires the Facility Security Officer to enter the supporting contract number drawn from the DD Form 254. Absent a DD Form 254 on this task order, an offeror has no compliant basis on which to initiate a Tier 3 national security investigation for a newly hired employee. The only remaining paths would be to staff exclusively with personnel already holding Tier 3 eligibility from unrelated classified work, or to submit the request in DISS against a different contract.. Please clarify which of the following the Government intends: (a) the task order does involve access to classified information, in which case a request that the DD Form 254, FAR 52.204-2, the facility clearance and safeguarding requirements, and the classified performance locations be issued with the solicitation so offerors can assess eligibility before quoting; or (b) the task order does not involve access to classified information, in which case a request that the Tier 3 and VROC references be removed and replaced with the correct credentialing and position designation requirements.
This will be reviewed and updated, if required, in the forthcoming solicitation.
29
D
Security / QASP
Position Designation, Investigative Tier, and Effect on Competition and Cost
If no classified access is required, the applicable vehicle for installation and unclassified system access is HSPD-12 credentialing, which requires a favorably adjudicated Tier 1 investigation for CAC issuance, with a higher tier applied only to positions formally designated as privileged information technology positions and adjudicated for fitness rather than national security eligibility. The QASP reference to Tier 3 for IT Level II suggests position designation, but that reading conflicts with the VROC reference in the Security section. Note the Security section in the current contract also cites JPAS and the SSBI and NACLC investigation types, all of which have been superseded, which suggests the section may not reflect current policy. Please provide the position sensitivity and information technology level designation assigned to each labor category, and confirm for each the minimum investigative tier and the adjudicative standard applied. There are two identified consequences for the Government's consideration. First, requiring Tier 3 eligibility on an unclassified requirement effectively limits competition to offerors able to field already-cleared personnel, which is difficult to reconcile with an unrestricted, full and open acquisition. Second, cleared labor carries a market premium that every offeror must carry in its cost proposal, so the Government would pay a clearance premium on a task order with no classified work.
This will be reviewed and updated, if required, in the forthcoming solicitation.
30
D
Time Attestation
The Government Timekeeping System Is Not Named
The PWS requires contractor personnel to sign in and out on arrival and departure using the timekeeping system provided by the Government, and the QASP references an attestation tracker, but neither names the system. Please identify the system by name and confirm: (a) whether it resides on NMCI, the ITC standalone network, or a public-facing site; (b) whether CAC authentication is required; (c) who provisions and supports accounts and how quickly; and (d) whether the system has a current authorization to operate. This is material because the PWS states that NMCI accounts require activity at least every 29 days and that an account deactivated for inactivity may not be restored. Please also confirm that the contractor's DCAA-compliant timekeeping system remains the official record for costs billed, with attestation serving as Government surveillance, and describe how discrepancies between the two records will be reconciled.
We are currently using a paper attestation system until we identify a feasible electronic system
31
D
Course Presentation / Deliverable Table
No Government-Furnished Property List
The PWS authorizes use of Government-furnished simulators, trainers, and ground-based systems whose types, quantities, and configurations may vary or be updated at any time, and separately holds the contractor accountable for issued property and subject to a Contract Discrepancy Report for unreturned items. No GFP attachment, inventory, or property clause is referenced. Please confirm whether a GFP list will be provided as a Section J attachment, whether FAR 52.245-1 will apply, and how contractor liability for loss or damage will be limited consistent with that clause.
NETSAFA ITC's GFP is inventoried and audited by NETSAFA Supply Manager; FAR clause 52.245-1 and a list of GFP will be included as needed.
32
D
Technical and Operations Support
ITC Network Authorization and TRANET Migration Scope
The System Administrator position is responsible for the ITC standalone network and government-furnished equipment. Industry day confirmed the ITC network is not connected to NMCI or TRANET and that transition to TRANET has been discussed but not implemented. Please clarify whether cybersecurity authorization support, plan of action and milestones execution, and any TRANET migration support fall within task order scope. If they do, please confirm the intended level of effort, since one System Administrator FTE cannot execute an authorization package concurrently with daily operations and support at two sites.
When TRANET is implemented, we anticipate the Sys Admin position to be removed as that function will shift to TRANET support. If applicable, other functions will be reassigned as needed. No TRANET implementation date is available.
33
D
Security / Personnel Qualifications
Contractor Grant of Access to Government Data
The PWS states that the contractor shall not grant contractor employees access to NETSAFA data or facilities without prior vetting and explicit approval from the COR. The contractor has no ability to grant access to Government facilities, systems, or data; those actions are inherently governmental and are executed by the Government.
The forthcoming solicitation will bw clear on its face.
34
E
Industry Day – Mission Support Versus Unique Services
Kuwait Country Liaison Office Support
The Officer in Charge briefed that the ITC supports three resident country liaison offices, including the Kuwait Air Force. Mr. Pruschen subsequently stated that a Kuwait office exists but is not supported under this contract. The PWS lists administrative assistant positions only for RSAF and RSNF. Please confirm whether Kuwait CLO administrative support is within scope, and separately confirm that instructional support to Kuwaiti students, who are currently enrolled in Fundamental Skills Training, remains in scope regardless of the CLO support determination.
The Kuwait CLO admin support personnel are not included on this contract. Instructional support of Kuwaiti students is in scope as part of providing FST on individually provided ROMs.
35
E
Educational and Training Services Versus Deliverable Product
Curriculum Development Scope Versus One Curriculum Manager
The PWS states that training will be delivered using Government-furnished curriculum, and industry day confirmed the current catalog is developed. The Educational and Training Services section, however, requires front-end analyses, curriculum design, program of instruction development, interactive courseware and computer-based training development, media and modality selection, development of a curriculum management policy and standard operating procedures, and an annual state-of-the-curriculum analysis with 12-to-24-month and three-to-five-year recommendations, all in accordance with NAVEDTRA M-142. That is a full instructional systems design effort across more than twenty courses against a single one-FTE Curriculum Manager. Please clarify whether the recurring baseline is end-of-course review and maintenance, with development efforts funded separately through the ROM process, or whether continuous development is expected within the NTE ceiling.
Depending on International Partner requirements, the need to develop new courses of instruction could arise at which time a determination will be made as to if it will be ROMd on the current contract or provided via a separately awarded action. Any development will be IAW the current NETC M-142 standards regardless of source. End-of-course review and maintenance will be included in ROM cost.
36
E
Contract Work Hours
Billable Hour Basis, Holidays, and Government-Directed Closures
Each full-time position is stated as 1,920 hours annually against a 2,080-hour work year. Please confirm whether 1,920 represents billable hours net of the eleven federal holidays and leave, and confirm whether scheduled federal holidays are billable. The PWS states that unscheduled temporary holidays are not billable, that telework is not authorized, and that closures for severe weather or emergencies are at the sole discretion of the Government. For a Pensacola and Whiting Field workforce subject to hurricane closures, please clarify the cost treatment when the Government closes the place of performance, consistent with FAR 52.242-15 and excusable delay principles, and confirm whether telework may be authorized in advance for positions capable of performing during a closure.
1,920 Hours will be used as the standard government contracting billable/productive FTE hours. This incorporates the 11 federal holidays.
37
E
Contract Work Hours / Transportation Support
After-Hours Transportation and Overtime Authorization
Transportation support is required Sunday through Saturday and expressly includes medical, dental, emergency room, and after-hours student movements, while overtime is described as not anticipated and requires prior COR approval. The Driver labor category is capped at 1.5 FTE and a qualified Class B CDL backup driver is also required. Please clarify (a) how emergent after-hours movements are authorized when prior approval is impractical, (b) whether a standing authorization or on-call arrangement will be established, and (c) whether 1.5 FTE is intended to cover seven-day availability plus a qualified backup.
(a) wording will be improved to account for situations when prior approval is impractical, (b) TBD, and (c) the FTE count provided is a representative estimate based on historical data.
38
E
Travel and ODCs
Refundable Reservation Mandate and Student Travel Funding
The requirement that all travel reservations be refundable conflicts with FAR Part 31 and JTR cost principles, materially increases consumption of the travel NTE, and is difficult to reconcile with the direction that ROMs contain no contingency. We request the Government accept lowest logical airfare with change and cancellation fees treated as allowable costs when Government-directed schedule changes occur. Separately, please confirm whether international military student travel and lodging for capstone courses are contractor-billed ODCs or Government-funded through Invitational Travel Orders, since this determination significantly affects the ODC NTE and offeror working capital assumptions.
PWS will be reviewed to ensure compliance with FAR part 31 and JTR. IMS travel and lodging are not contractor-billed. IMS travel is through the government only and unrelated to ODCs
39
E
Personnel Qualifications
Qualification Statements Requiring Correction
Several qualification statements appear internally inconsistent or exceed the instructional scope and will increase cost without corresponding benefit: (a) the Pilot Instructor minimums of 1,000 flight hours, 400 hours flight experience, and 250 pilot-in-command hours are not internally consistent as written; (b) the NFO/WSO section requires at least two instructors FAA-qualified to instruct and certify in-flight civilian private pilot training, although no in-flight instruction appears within the PWS scope; (c) the Technical and Specialized Training Instructor requires Myers-Briggs Type Indicator certification with legal experience preferred, neither of which maps to a stated course objective; and (d) the System Administrator requirement reads 'Security+ certification AND ___ years of experience,' with the numeral omitted. Please correct these items and confirm whether listed certifications must be held at quote submission or may be obtained within a defined period after award.
Will be verified and updated, as required.
40
E
Period of Performance
Option Period Dates
The PWS lists OY3 as 1 March 2031 through 31 August 2031, which leaves a twelve-month gap following the end of OY2 on 28 February 2030. Please confirm the intended FAR 52.217-8 period is 1 March 2030 through 31 August 2030, and confirm whether offerors are to separately price the six-month extension for evaluation.
Solicitation will list the correct PoPs as this contract will be solicited as a full Base Plus four option years with an additional 6-month FAR 52.217-8 Option. The 6-month -8 option should be separately priced and this will be stated in the solicitation.
41
E
Transition Plan
Phase-In Period and Clearance Reciprocity
The Transition Plan addresses incumbent phase-out only. Given a 1 March 2027 start and the requirement for fully manned, vetted, CAC-holding, course-certified instructors on day one, please confirm whether a phase-in period will be established between award and performance start, whether phase-in is separately funded, and whether the Government will accept reciprocity of existing favorable adjudications through DISS to avoid an interruption in the international student training pipeline. Please also confirm the disposition of the current task order, N0018924F3006, and whether any overlap is planned.
The NAVSUP FLCN Contracting Office is estimating a 30–45-day transition period allowing for the awardee and NETSAFA to phase-in and get all required vetting and access prior to contract start if required. The phase-in stage is not anticipated to have any associated costs. NETSAFA will not cover any potential costs resulting from administrative work prior to contract start. No overlap is anticipated. However, this is subject to change.
42
E
Waivers and Exceptions
Equitable Adjustment of Salary Language
The PWS states that the Government reserves the right to request an equitable adjustment of salary equivalent to the contractor employee's education and experience level. Employee compensation is set by the contractor subject to applicable wage determinations and cost principles. If the intent is a downward adjustment to a billed labor rate when the Government waives a qualification, we request the provision be restated in those terms. Please also confirm whether a Service Contract Act wage determination will be incorporated, and identify the covered positions.
Will be reviewed and properly stated in the solicitation
43
E
Transition Plan
Funding and Coordination of Incumbent Phase-Out
The Transition Plan directs phase-out support to the incoming contractor at least 30 days prior to the end of the final period of performance. The incumbent is not a party to the resulting task order and cannot be bound by it. Please confirm how incumbent phase-out support will be authorized and funded, whether through a modification to the incumbent's existing task order or by other means, and identify the Government office responsible for coordinating the two contractors. Please also confirm what specific artifacts the Government expects to transfer, including curriculum baselines and version control, test banks, student records, GFP inventories, network administration credentials, and vendor and guest speaker points of contact, so that both the outgoing and incoming contractors work from the same list.
Will be reviewed and properly stated in the solicitation
44
E
Section I / Workforce
Nondisplacement or Right of First Refusal
Please confirm whether any nondisplacement of qualified workers provision, right of first refusal, or similar successor-employment requirement will apply to this task order, and if so, identify the clause and the covered positions. This determination materially affects both the incoming contractor's staffing assumptions and the continuity of instruction for international students currently in the training pipeline.
The forthcoming solicitation will be clear on its face.
45
E
List of Acronyms
Editorial Corrections
The acronym list contains several errors that should be corrected before release, including NFO listed as Naval Flight Instructor rather than Naval Flight Officer, API listed as Aviation Pre-Flight Doctrinarian rather than Indoctrination, RSAD listed in place of RSAF for Royal Saudi Air Force, VAR listed as Visitation Access Request rather than Visit Authorization Request, JPAS listed as Joint Personnel Adjunction System rather than Adjudication, MPAS defined incompletely as Mission Partner, and retention of the superseded SSBI and NACLC investigation types alongside the current Tier 3 standard.
These will be corrected at the time of solicitation.
46
F
Industry Day
Historical Utilization and Throughput
Mr. Pruschen took an action item to determine whether historical convening data could be released. Please provide, for the most recent three years, the number of course convenings actually conducted by course, the number of students enrolled and graduated, and the number of scheduled convenings that were cancelled. Please also provide, for the same period, the number of scheduled convenings cancelled after funds were obligated, the number cancelled after the contractor had begun performance, the average advance notice provided, the total dollar value deobligated from cancelled or under-enrolled requirements, and the rate of student no-shows measured against the enrollment on which each ROM was priced. Because the published schedule is expressly non-binding, because industry day described current utilization as in a downswing, and because cancellation and no-show frequency drive unrecovered cost under the per-student allocation model, offerors have no other basis on which to estimate actual workload or cost risk.
In work with NETSAFA ITC staff.
47
F
Personnel Qualifications
Incumbent Staffing Baseline
Please provide current staffing by labor category, showing authorized NTE FTE against actual FTE utilized over the most recent twelve months. The NTE ceilings in the PWS establish a maximum, not an expected level, and the difference between the two drives the entire cost proposal. Without this, offerors must either price to the ceiling, which overstates cost to the Government, or guess low and staff inadequately.
The forthcoming solicitation will be clear on its face.
48
F
ROM Process
ROM and Modification Volume
Please provide, for the most recent twelve months, the number of ROMs issued to the contractor for pricing, the number that resulted in a funded modification, the number of modifications issued, and the average elapsed time from ROM issuance to modification. This data sizes the administrative and program management effort, which is otherwise unquantifiable from the PWS.
This will be provided as part of the solicitation if requested as part of that process.
49
F
Travel and ODCs
Historical Travel and ODC Actuals
The Travel and ODC not-to-exceed tables are populated with placeholders. Pending resolution of those values, please provide actual travel and ODC expenditures for the most recent three years, broken out by capstone course travel, Mobile Training Team travel, and student transportation, so offerors can assess exposure and validate the ceilings once published.
This will be provided as part of the solicitation if requested as part of that process.
50
F
Industry Day
Guest Speaker Roster
The Government indicated the guest speaker list would be shared after award. Because the PWS identifies guest speakers as a means of covering specialized capstone content and as a mitigation for cancellations, the availability and cost of those speakers is a pricing input rather than a post-award administrative detail.
The forthcoming solicitation will be clear on its face.
Is the Government Interested in publishing a list of Vendors for Teaming purposes?
The Government will not be providing this information at this time.
How countries are included in the program?

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