QA_Q1-2_AMD 0001.pdf
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- Solicitation number
- N62742-26-R-1801
About this file
This is a Questions and Answers document for Solicitation No. N62742-26-R-1801, a Small Business Indefinite Delivery Indefinite Quantity (IDIQ) contract for Environmental Remedial Action for sites in Hawaii, Guam, and other areas within the Naval Facilities Engineering Systems Command Pacific Area of Responsibility.
The document addresses two primary inquiries from potential offerors. The first question confirms that this is a recompete effort, with the current incumbent being CAPE-WESTON JV3 LLC operating under Contract Number N62742-22-D-1800. The second question concerns cost proposal requirements related to purchasing systems and Cost Accounting Standards compliance. The original solicitation required all offerors to possess a Government-approved purchasing system reviewed and approved in accordance with FAR Part 44 prior to contract award, with non-compliance potentially resulting in proposal rejection. In response to concerns that this requirement creates barriers for small business participation, the Government issued Amendment 0001 revising the solicitation. The revised approach allows offerors without formally approved purchasing systems to submit purchasing-system policies, procedures, internal-control documentation, audit results, and past-performance information for evaluation as part of the responsibility determination, and permits application of consent-to-subcontract requirements under FAR 52.244-2 to awardees lacking approved purchasing systems until formal approval is obtained. This modification preserves small business competition while maintaining appropriate government protections.
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N62742-26-R-1801 Amendment 0001
Q ue st io n
Reference/ Section Question Government Response
Is there any incumbent/recompete or this is a brand-new project? If yes, could you please provide us with their award number or even if the customer bought similar services in the past.
The requirements listed in this solicitation are currently being provided by contract. The current incumbent is CAPE-WESTON JV3 LLC, operating under Contract Number N62742-22-D-1800. This acquisition is being solicited as a Small Business Set-Aside, and all qualified offerors are encouraged to submit proposals.
Section L, Cost Proposal, Section II, Tab 3 Contractor Business Systems and Cost Accounting Standards (CAS)
The solicitation states that all offerors must possess an acceptable purchasing system that has been reviewed and approved in accordance with FAR Part 44 by a Cognizant Federal Agency Official prior to award of the Basic Contract. It further states that an offeror’s cost proposal may be rejected if the offeror does not have a Government-approved purchasing system prior to award.
Please clarify whether the Government would consider revising this requirement to permit responsible small business offerors that do not currently possess a formally approved purchasing system to demonstrate the acceptability of purchasing policies, procedures, internal controls, and prior subcontract-management performance through the proposal.
Formal purchasing-system approval requires a Government-conducted Contractor Purchasing System Review (CPSR) and a determination by the cognizant contracting official. The scheduling and initiation of a CPSR are entirely within the Government's purview, and per DCMA guidelines, small businesses generally cannot self-initiate a CPSR without prior agency sponsorship and crossing specific sales thresholds. Consequently, requiring formal pre-award approval creates an insurmountable barrier for small businesses and may unnecessarily restrict competition by excluding experienced small business contractors that maintain compliant purchasing systems but have not been selected by their cognizant agency for a
CPSR.
To preserve small business participation and competition while providing appropriate protection to the Government, please consider the following alternatives:
•Allow offerors without a formally approved purchasing system to submit their purchasing-system policies, procedures, internal-control documentation, prior audit or review results, and relevant past-performance information for evaluation as part of the responsibility determination;
•Apply the consent-to-subcontract requirements of FAR 52.244-2 to an awardee that does not yet possess an approved purchasing system until formal approval is obtained (per FAR 44.201-1, which explicitly provides for this mechanism when a purchasing system is not approved).
Please see revised soliciation via Amendment 0001.
Solicitation No. N62742-26-R-1801, Small Business Indefinite Delivery Indefinite Quantity (IDIQ) Contract for Environmental Remedial Action for Sites in Hawaii, Guam, and Other Areas within the Naval Facilities Engineering Systems Command Pacific Area of Responsibility
QUESTIONS AND ANSWERS
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