Question and Answers_Draft Solicitation_W91CRB24R0013.pdf

Army Audited Financial Statement Compilation and Publication W91CRB‐24‐R‐0013 – DRAFT Solicitation Questions and Comments

DRAFT Solicitation Posted: 07 February 2024 / Comments Received 20 February 2024

No. Category DRAFT RFP Part & Section Reference

DRAFT RFP

Page

Questions/Comments/Clarification Government Response

1 SF1449 1 Based on the size and scope of work, recommend the acquisition remains a SB set aside. There are several SB IPA firms that can perform this work.

The government strategy for this action is a total small business set‐aside.

2 # of FTEs Place of Performance 16 Please specify the number of personnel needed at the Taylor Building in Crystal City.

Contractor staff needs to be available for in person meetings as needed. Information related to this is in section 1.6.5 of the PWS, which indicates the Program Manager will be assigned to the Taylor Building and that the remaining contractor personnel shall work at any of the three (3) locations (DFAS‐Indianapolis, DFAS‐ Columbus, or at Army Headquarters (Taylor Building).

3 Personnel 20, paragraph 4, 1st sentence

Considering the Federal Government agency financial statement compilation process is consistent across the federal government, would the government considering changing the language to include “or similar systems”.

The Government is specifically looking for DoD or Army experience.

4 SOLICITATION/CONTRACT/ORDER

FOR COMMERCIAL ITEMS,

STANDARD FORM (SF) 1449 BOX

1 The meticulous creation of financial statements for Department‐level Government agencies requiring high‐level expertise and a multitude of experience requirements often make the production of detailed departmental financial statements a challenging proposition for small businesses who may have limited manpower and financial resources. Small businesses often lack the specialized knowledge, or the financial infrastructure needed to generate comprehensive reports that meet the stringent reporting requirements and the complexity of financial statement preparation standards set by Department‐level Government entities.

Given these challenges, Department‐level agencies have not historically hired small businesses to prepare and compile the consolidated Agency Financial Report (AFR). No Department of Defense

The government strategy for this action is a total small business set‐aside.

(DoD) component has hired a small business to prepare and report their AFR, and we are unaware of any other Chief Financial Officers Act of 1990 (CFO Act) Agency that has either.

We believe the size and scope of the United States Army (Army) Audited Financial Statements Compilation and Publication effort would be better suited for a large business. Given the delivery requirements, inherent schedule constraints, technical obligations, information security, and due diligence considerations, we believe an award to a small business may present undue risk to the Government in the form of recruiting and talent management gaps, lack of expertise and corporate reach‐back capability, onboarding delays, schedule slippage, procurement delays, transition risks, and the lack of a bench, requiring the involvement of large firms to provide staffing, thus negating small business goals. Further, if awarded to a large business, the Government can require a Small Business Subcontracting Plan or small business participation goals; this way, the Government’s goals would be directly addressed.

5 Section 3 – Management Plan 67 The Government’s recommended staffing mix is based on work efforts from previous Requests for Proposal (RFP). It is in the Government’s best interest to allow vendors to provide their own staffing mix to best capture expertise, support staff, and technological efficiencies. As the Army moves toward accomplishing goals, the staffing mix will (and has) changed. The necessity for junior personnel has decreased, as requested by current Government staff, and the need for more technical senior personnel has increased. Additionally, as the efficiencies currently in place take hold, we can then leverage junior personnel as deemed appropriate by

There will be no changes to the prescribed staffing mix at this time.

the Government staff and reallocate senior personnel to higher‐priority tasks.

Allowing the vendor to dictate the staffing mix does not impact the cost to the Government as price will be independently evaluated. Instead, it allows vendors to create the most effective and efficient team, providing the most value.

6 Section M – Basis for Award 75 This solicitation should be evaluated based on what truly matters to the Army: will the professional staff who show up have true, proven experience in remediating material weaknesses or issuing audit opinions that included findings/weaknesses? The evaluation criteria should be weighted to ensure the Army gets the people it needs to be successful. A simple trade‐off of technical/past performance/price does not ensure the right answer for the Army. Best value matters, as bidders attempting to bid lower than realistic rates and change orders later is not the ideal solution for the Army.

We recommend adjusting the Factors to:

1. Key Personnel – Key personnel lead our efforts because it is important to have experts who have already solved Army‐specific challenges, which translates to “no guess work.” For this reason, key personnel should be evaluated as more important than the technical approach and adjectively rated in tradeoff evaluations.

2. Past Performance – A simple “size, scope, complexity” comparison will not achieve the Army’s goals for an auditable financial statement opinion.

Demonstrating successful audit readiness support that achieved results should weigh heavily in the Government’s evaluation criteria. Offerors should be required to demonstrate experience providing audit readiness support or performing financial statement audits for DoD and other Federal agencies. At least one or two of the required past performance

Evaluation factors have be determined by the requiring activity in conjunction with the contracting activity and approved by the source selection authority (SSA).

citations required should be serving as the financial statement auditor for a relevant DoD or Federal civilian agency.

3. Technical – All Certified Public Accounting (CPA) firms will submit compliant technical approaches following Generally Accepted Accounting Principles (GAAP), Generally Accepted Government Auditing Standards (GAGAS), Federal Accounting Standards Advisory Board (FASAB), and other Financial Management Regulation (FMR) requirements.

Therefore, this factor could be rated acceptable or unacceptable (pass or fail) or utilizing adjectival ratings in trade‐off evaluations.

4. Price – The Government should require vendors to submit pricing using their approved General Services Administration (GSA) Multiple Award Schedule (MAS) rates, which are considered fair and reasonable by GSA. Proposed discounts should be evaluated based on price realism, ensuring vendors provide an explanation for why they believe their rates are realistic in terms of being able to recruit and retain qualified personnel to perform services described in the Army’s Performance Work Statement (PWS).

7 1.1 (Description of Services)

1.4 (Scope)

14 1.1 states “non‐personal services necessary to prepare and publish the Army’s General Fund, Working Capital Fund, and Civil Works Fund quarterly and annual Financial Statements as defined in this Performance Work Statement”

Additionally, 1.4 states “Scope includes the Army General Fund Financial Statements and the Army Working Capital Fund Financial Statements”

Would the Government please confirm if the scope will include Civil Works Fund (Quarterly) as described in section 1.1?

The Army General Fund and Working Capital Fund require quarterly support for the creation of the financial statements. The Army General Fund, Working Capital Fund, and Civil Works Fund require annual support for the creation of the Annual Financial Report. Updated PWS section 1.1 to read as follows:

“Description of Services/Introduction: The contractor shall provide all personnel, equipment, supplies, facilities, transportation, tools, materials, supervision, and other items and non‐personal services necessary to prepare and publish the Army’s General Fund and

Working Capital Fund quarterly financial statements, and the Annual Financial Report for Army’s General Fund, Working Capital Fund, and Civil Works Fund as defined in this Performance Work Statement except as specified in Part 3 as Government furnished property and services.

The contractor shall perform to the standards in this contract.“

8 1.6.13 Personnel: 20 1.6.13 states “The contractor firm shall have a least one year’s recent experience working with the Army, Defense Finance and Accounting Service (DFAS), and Office of the Secretary of Defense (OSD) systems used to produce the Army Financial Statements.”

To provide open and fair competition, we recommend the Government update this requirement to not limit the requirement at the firm level and instead, allow for firms to leverage personnel expertise from prior employers to evidence one year of experience working with Army, DFAS, and OSD systems used to produce the Army financial statements.

PWS section 1.6.13 has been updated to align requirements to personnel instead of firm.

9 5.3.5.1 (Audit Readiness Support) 31 5.3.5.1 states “Contractor shall provide audit support for critical new requirements identified by Army that are unknown at this point. These emerging requirements will still be considered within the scope of the contract if they are associated with audit facilitation and remediation activities.”

The Government should consider adding an Optional Time and Materials CLIN to enable the offerors to deliver the right resources to meet the Government’s emerging future needs.

At this time, the government‘s prescribed level of effort encompasses tasks to be completed. Unforeseen fluctuations that may arise in the future, may be addressed via a contract modification.

10 Various Volume 1 (section 2) DoD/Federal Government Experience states “1. Offerors shall submit a

Volume 1, Section 2 has been updated to indicate a recent contract is defined as one that minimum of three (3), but no more than six (6) project descriptions that clearly demonstrate the offeror’s prior DoD/Federal Government experience that is relevant to this requirement. Projects may be past (completed within the past 36 months) or current,”

Volume 3 – Factor 2 (Past Performance) states “Offerors shall provide narrative descriptions for up to three (3) contracts for the prime Offeror and no more than two (2) for each major subcontractor of performance during the past five (5) years from the date of issuance of the final solicitation, which are relevant to the services and supplies required by this solicitation.”

Would the Government please clarify the number and time frame for past experience references required from Offerors?

has performance during the past three (3) years.

As per Section 2 – DoD/Federal Government Experience indicates, a minimum of 3 past performance records are required but no more than 6. As a point of clarification, the technical volume is referring to experience while the past performance volume is looking at how well and offeror performed on recent and relevant contracts. These two proposal requirements have different constraints that are defined in their respective volumes.

11 PROPOSAL CONTENT

REQUIREMENTS

72 Volume 4 (Factor 3 – Price) states “For all Key Personnel, as specified in the PWS, the Offeror shall include signed letters of intent (one page maximum) for those who are not currently employed by the Offeror and shall include individuals name, contingent start date, salary amount and position/title. The letters of intent with un‐redacted salary amount shall be included in an appendix to the price proposal narrative volume.”

Given the Firm Fixed Price nature of the solicitation, would the Government remove the requirement to provide the un‐redacted salary amount.

The government has removed the requirement for un‐redacted salary from Volume 4.

12 1.4 (Scope) 14 This section states, “Contractor will also assist the Army in preparing briefings on the financial statements as well as on other financial statement related deliberations and decisions.”

PWS Section 1.4 Scope remains unchanged as the number can vary.

We recommend the Government include additional information on the number of briefings and related deliberations and decisions the Contractor will be expected to work on each year.

13 1.6.5 (Hours of Operation and Place of Performance)

16 This section states, “The remaining contractor personnel shall work at the Army Headquarters with the Army Financial Statement team, currently at 2530 Crystal Drive, Suite 400, Arlington, VA (Taylor Building).”

We recommend the Government add what is the total count of the remaining contractor personnel that would work in Arlington, VA.

Updated the PWS 1.6.5 to read:

“Up to four (4) contractor personnel can be assigned to work daily at DFAS‐Indianapolis, and up to two (2) contractor personnel can be assigned to work daily at DFAS‐Columbus. The remaining contractor personnel shall work at any of the three locations (DFAS‐ Indianapolis, DFAS‐Columbus, or the Army Headquarters, currently at 2530 Crystal Drive, Suite 400, Arlington, VA (Taylor Building)) deemed appropriate. “

14 1.6.21 (Other Direct Costs) 22 This section states, “This category includes travel (outlined in 1.6.13), reproduction, and shipping expenses associated with publishing the annual financial report.”

Would the Government please confirm that all costs associated to the production of annual reports for the General Fund, Working Capital Fund and Civil Works Fund are to be included as an ODC and priced as a component of CLIN 0002, using the fixed amount required in the solicitation?

The government confirms that all costs associated with the production of the annual General Fund, Working Capital Fund, and Civil Works fund are to be included in the Other Direct Costs CLIN. A normalized amount for ODCs will be provided at time of solicitation.

15 Acquisition Type

Standard Form 1449 1 Given the scope’s high visibility, complexity, anticipated team size, team presence in multiple geographic locations, IPA firm requirement, and past performance experience expectations, recommend the Government consider an unrestricted, full and open competition type to provide the Army access to the most capable and experienced IPA firm.

The government strategy for this action is a total small business set‐aside.

16 Scope 1.4 Scope 15 Scope indicates that it includes the Army General Fund and the Army Working Capital Fund Financial Statements, as well as “working with the U.S Army Corps of Engineers to create its annual Civil Works Financial Statements publication.” Could additional details be provided to clarify the level of effort involvement associated with working with USACE on the Civil Works statements?

PWS section 5.1.1 The level of effort associated with the USACE is similar to that associated with the Army General and Working Capital Funds for the Annual Financial Report. The vendor will be required to prepare, compile, and publish the report using information provided by the USACE.

17 Place of Performance

1.6.5 Hours of Operation 16 Are the key personnel required to have their primary work location at 2530 Crystal Drive, Suite 400, Arlington, VA (Taylor Building)? Additionally, this section discusses support being required at the Taylor Building “if sufficient facilities are available” and if not, then “personnel shall be available by TEAMs (or other DOD authorized group meeting software), telephone, and e‐mail during the hours listed above.” Could the Government confirm if this means resources are able to support remotely if space is not always available at the Taylor Building?

PWS section 1.6.5 The Government will always have sufficient facilities available but telework is available unless specific tasks require in person attendance at the Taylor Building. The only Key personnel required to have their primary work location at 2530 Crystal Drive is the Program Manager.

18 Quarterly Support Schedule

1.6.5 Hours of Operation and

Place of Performance

16 This section indicates that “contractor personnel shall be available 8:00 AM thru 8:00 PM EST for 21 days beginning with any quarter month”, however, sections 1.4 Scope and 1.6.4 Recognized Holidays note just 14 days. Could the government please clarify if the expectation is 14 or 21 straight days of 12‐hour support following each quarter‐end?

Updated PWS section 1.6.5 to reflect “up to 21 days”

19 Contractor Firm Requirements

1.6.13 Personnel 20 This section indicates that “The contractor firm shall have a least one year’s recent experience working with the Army, Defense Finance and Accounting Service (DFAS), and Office of the Secretary of Defense (OSD) systems used to produce the Army Financial Statements.” This requirement reads overly restrictive as experience that would only be available to the incumbent who has been able to recently work with Army systems to produce Army Financial Statements. Suggest the Government modify this requirement to include experience

PWS Section 1.6.13 updated to “The contractor shall have personnel assigned that are Certified Public Accountants who are in good standing with the AICPA and applicable state boards. All contractor personnel supporting this requirement shall also be citizens of the United States.”

producing financial statements for any of the Military Departments and/or Defense Agencies.

20 Contractor Personnel Requirements

1.6.13 Personnel 20 This section notes for all contractor personnel, “The proposed substitution of personnel must meet or exceed the education, experience, knowledge and other technical requirements of the personnel being replaced.” Recommend this be adjusted to state that any proposed substitution must meet the labor category requirements for the position being filled, in order to maintain alignment with contract requirements and avoid an escalation in skillsets if the original staff member exceeded the LCAT requirement.

Section wording has been removed. PWS section 5.8.1 updated to ‐ “Prior to substituting, removing, or replacing any personnel, the Contractor shall notify the Contracting Officer and Contracting Officer Representative in writing (including proposed substitutions).”

21 Contractor Personnel Requirements

1.6.13 Personnel, 1.6.14 Key

Personnel Qualifications

20, 21 These sections note that for the three years noted experience with SAP, “At least two of those years shall be experience with General Fund Enterprise Business System (GFEBS), Global Combat Support System (GCSS) Army, Logistics Modernization Program (LMP), or other DOD system based on SAP.” Suggest that experience should not be limited to just DoD systems, as various non‐DoD (Civilian) Federal and Commercial entities leverage SAP with the same functionality that would provide a resource with commensurate experience.

Qualified personnel will have 3 years SAP experience, with at least 2 of those years being specific to an Army SAP system..

22 Contractor Personnel Requirements

1.6.14 Key Personnel

Qualifications

21 What are the qualification expectations for the “financial statement publisher” role?

PWS section 5.8.3 Labor Category Requirements updated to include: The Professional Publisher shall have a degree in technical writing or degree in a publishing related field. The Professional Publisher shall have at least 3‐4 years’ experience in publishing. The Professional Publisher shall have documented experience in publishing financial statements, including composition and editing. (There is no role for a financial statement publisher.)

23 Task Scope 5.2, 5.2.1 29 Could the Government provide additional details to specify the scope and assist in determining quantity/frequency/level of effort associated with 5.2 and 5.2.1 tasks, as well as what will be the deliverable format requirement to evidence support provided under 5.2 and 5.2.1 task areas?

As the quantity and frequency varies, the government is not able to provide additional details at this time.

24 Task Scope 5.3.2 Journal Vouchers (JVs) 30 Is the Government able to share how many monthly and quarterly journal voucher packages are currently prepared by DFAS that are in scope of this task area?

As the quantity varies period to period, the government is not able to provide additional details at this time.

25 Task Scope 5.3.3.1 Monthly Analysis Reviews 30 For the listed 5.3.3.1 deliverables, are prior examples/templates completed for these, or do any require development of format and approach for the first time? Additionally, how many reconciliations are in scope for the noted monthly “review reporting reconciliations”?

For the specific deliverables listed, there are examples from previous periods that the Government may provide. The number of reconciliations varies from period to period.

26 Optional CLINs 5.6 Optional Contract Line Items (CLINs)

33 How and when will the Government determine if these Optional CLINs will be used? Will these Optional CLINs be separated in the pricing template of the final solicitation to have separate FFP pricing?

What will be the deliverable format and frequency requirement to evidence support provided under 5.6/5.6.1?

PWS section 5.6 that included Optional CLINS and AWCF posting logic has been removed from the PWS.

27 Past Performance

Volume 2, Section 2 66 Due to the DRAFT watermark, can’t fully see, but it looks like this section may state that “Projects may be past (completed within the past 3 months)…”. If so, highly recommend that the length of time for usage of a past project be extended beyond just 3 months as this is very limiting in what past performances are available to use and would restrict consideration of highly relevant past experience that would demonstrate a firm’s ability to support this current requirement.

Section 2 states “projects completed within the past 36 months”. This has since been updated to 60 months, please see question 32.

28 Past Performance

Volume 2, Volume 3 66, 67 Could the Government clarify if/what differences in intent and requested information exist between the Volume 2, Section 2 – DoD/Federal Government Experience and Volume 3, Factor 2, Past Performance requirements, as both appear to be

These are two different requirements that seem similar but actually have different purposes.

Volume 2, Section 2 evaluation focuses on the type of experience a vendor has which is evaluated as part of the Technical Rating.

requesting similar past performance information?

Volume 3, Section 2 evaluation focuses on past performance and how well a vendor performed.

29 Letters of Intent Section 3 – Management Plan, Key Personnel; Volume 4 – Factor 3 – Price

68 Suggest that the requirement to include un‐redacted intended salary amounts within any Letters of Intent and/or the Price Volume be removed, as this would not appear necessary to inform alignment with the Key Personnel LCAT requirements and FFP model.

The government has removed the requirement for un‐redacted salary from Volume 4.

30 Past Performance

Factor 2 – Past Performance 78 This section states, “All past performance examples should be where the Offeror or major subcontractor performed the work as the prime contractor.”

Recommend that this requirement be updated to allow for the Offeror and major subcontractors to submit past performances in which they performed the work as a subcontractor, as this will otherwise restrict inclusion of relevant past performances that would demonstrate to the Government a given firm’s/team’s ability to support this requirement.

Given the size and complexity of many DoD FM/accounting/audit readiness‐related contracts, performance as a subcontractor can be a significant, complex project experience and role commensurate with the nature of this requirement.

The resulting government contract is with the prime, therefore past experience as a prime will be evaluated.

31 PWS PWS 1.6.5 16 To allow for the greatest support to the Army and position the contractor to do so in the most efficient way, would the government consider the following?

“Up to four (4) contractor personnel shall be assigned to work at DFAS‐Indianapolis, and up to two (2) contractor personnel shall be assigned to work at DFAS‐Columbus or at an AMC location. The remaining contractor personnel can be assigned to work at the Army Headquarters with the Army Financial Statement team, currently at 2530 Crystal Drive, Suite 400, Arlington, VA (Taylor Building).”

PWS Section 1.6.5 has been updated to:

Up to four (4) contractor personnel can be assigned to work daily at DFAS‐Indianapolis, and up to two (2) contractor personnel can be assigned to work daily at DFAS‐Columbus. The Program Manager will be assigned at 2530 Crystal Drive, Arlington, VA (Taylor Building). The remaining contractor personnel shall work at any of the three locations (DFAS‐ Indianapolis, DFAS‐Columbus, or at the Army Headquarters at 2530 Crystal Drive, Suite 400, Arlington, VA (Taylor Building)).

32 Experience Volume 2, Factor 2, DoD/Federal Government Experience

66 In alignment with the small business set‐aside designation for this draft proposal and to be consistent with the “1.6.13 Personnel”, would the government consider updating the requirement to the following? “Offerors shall submit a minimum of three (3), but no more than six (6) project descriptions that clearly demonstrate the offeror’s prior DoD/Federal Government experience that is relevant to this requirement. Projects may be past (completed within the past 60 months) or current, but must be substantially the same in scope, size, and complexity as this requirement.

Volume 2, Section 2 has been updated to “Projects may be past (completed within the past 60 months) or current, but must be substantially the same in scope, size, and complexity of this requirement.”

33 Past Performance

Volume 3, Factor 2 Past Performance

70 In alignment with the small business set‐aside designation for this draft proposal and to be consistent with the “1.6.13 Personnel”, would the government consider updating the requirement to the following? “Offerors shall provide narrative descriptions for up to two (2) contracts for the prime Offeror and no more than three (3) for each major subcontractor of performance during the past five (5) years from the date of issuance of the final solicitation.

Volume 3, Factor 2 has been updated to “Offerors shall provide narrative descriptions for up to 3 contracts for the prime Offeror and no more than 3 for all major subcontractors of performance during the past 5 years from the date of issuance of the financial solicitation, which are relevant to the services and supplies required by the solicitation.

34 Overall Would the government consider allowing some credit or preference to small businesses with other disadvantaged program certifications (i.e. women‐ owned small businesses)?

The government will not be providing credit or preference to small businesses with other disadvantaged program certificates.