Question_Response_Matrix_PM_MAV_LFSS_RFP .xlsx

Instructions

2) LEVEL column-

3) Questions/Rationale column: provide clear concise question or recommended change to specific document reference (page, para, line). Rationale should clearly articulate purpose for change.

NOTE: Comments without rationale clearly explaining proposed recommendations or without citing any governing references are not useful. In general, format comments will not be categorized higher than Administrative unless there is a clear rationale how performance, interoperability, supportability, or other factors that may impact the potential success of the program .

Questions

The Government does anticipate utilizing contractor capabilities for structural repair and subsystem replacement. The contractor should have the capability to troubleshoot and repair Line Replaceable Units with electronic faults and isolate to the circuit card or Shop Replaceable Unit level utilizing Direct Support Electrical System Test Set.

The Government does anticipate utilizing contractor capabilities for survivability upgrades associated with fielding and sustainment programs.

The Final RFP will increase the number of contracts in L.4.1.1 from "three" to "five."

Section L.4.4.8 – Cost Accounting System 131 L.4.4.8 Critical An adequate cost accounting system verified by DCAA or DCMA is required for award eligibility. For offerors currently undergoing a system review, what documentation is acceptable at proposal submission? Clarifying the documentation required allows offerors to develop compliant cost proposals. If the offeror is currently undergoing a system review, the Government requests it provide a status of the review and DCAA POC information to the Contracting Officer. The scope will be updated in the RFP.

If the offeror has not began a system review, follow the procedures in Section L.4.4.8.

Section L.4.4.8 – Cost Accounting System 131 L.4.4.8 Critical An adequate cost accounting system verified by DCAA or DCMA is required for award eligibility. Will the Government allow submission of the final DCAA adequacy letter after proposal submission but prior to award? DCAA audits are significantly backlogged as a result of last fall's shutdowns, as well as ongoing budget constraints for several years. Section L.4.4.8 will be revised to provide clarification that the status of the offerors cost accounting system will be assessed during the PCOs responsibility determination. Therefore final DCAA adequacy letter documentation can be submitted as part of responsibility determination post proposal submission and prior to contract award.

The Final RFP will be revised to reflect this clarification.

(a) Are subcontractors permitted to propose their own separate indirect rates on Travel/ODC and Material within the GFPM-Subs (Attachment 0039) if an indirect ceiling rate is not proposed by the prime?

(b) How should the Prime's cost narrative disclose the split of the ceiling rate between Prime and subcontractor indirect expenses?

(c) If a subcontractor's actual indirect rate on Travel/ODC or Material exceeds the Prime's proposed ceiling, is the excess unallowable, and will the Government conduct a cost realism adjustment accordingly? Sections L.4.2.3.11.1 and L.4.2.3.12.2 state that the Prime offeror may propose a single indirect ceiling rate on Material and a single indirect ceiling rate on Travel/ODC that is "inclusive of any prime and subcontractor indirect expense." Section L.4.2.5.1.2.4 further states that the Prime is responsible for covering subcontractor indirect expenses from those ceilings. a) No. The proposed indirect ceiling rate on travel/ODC/material should reflect the maximum indirect rate for the prime and any potential subs.

b) The ceiling rate cannot be split between the prime and subcontractor. The offerors cannot propose separate indirect ceiling rates on travel/ODC/material for the Prime and Subcontractors. IAW L.4.2.3.11.1 and 4.2.3.12.2, this indirect rate is inclusive of any prime and subcontractor indirect expense that may be applied and reimbursed.

c) The proposed indirect ceiling rate on travel/ODC/material should reflect the maximum indirect rate for the prime and any potential subs.

Economic Price Adjustment Clause 52

128 L.4.2.4 L.4.2.4.3 L.4.2.5.1.2.2 L.4.2.5.1.2.3 L.4.2.7.1 Critical Please confirm:

(a) Are subcontractors without an adequate accounting system, DCAA audit history, or forward pricing rate data precluded from participating under this contract?

(b) If not, what alternative documentation or compliance pathway is available to such subcontractors to satisfy the proposal requirements in Section L.4.2.4 and L.4.2.5?

(c) Will the Government consider permitting the Prime to award fixed-price or Time-and-Materials subcontracts to subcontractors that cannot support CPFF cost reporting requirements, subject to Contracting Officer consent per FAR 52.244-2, as an alternative to excluding capable small businesses from participating? The solicitation creates a significant barrier for small business participation and may preclude otherwise qualified (and Army experienced) small business vendors from participating because the draft requires all subcontractors to provide full indirect rate transparency in the GFPM-Subs (Attachment 0039), including three years of historical indirect rate data, DCAA/DCMA points of contact, copies of any FPRP/FPRR/FPRA or provisional billing rates, and a complete labor rate build showing every element of cost. These requirements implicitly assume that all subcontractors possess an adequate accounting system as contemplated by FAR 16.301-3 - one capable of segregating direct from indirect costs, tracking costs by contract, and producing data sufficient to withstand DCAA audit scrutiny. However, many capable and otherwise qualified small business subcontractors do not have DCAA-audited or formally approved accounting systems, may not have three years of indirect rate history, and may not have an established relationship with a DCAA or DCMA office. The solicitation is entirely silent on what such subcontractors are expected to do, and provides no exception, waiver, or alternative compliance pathway for subcontractors that cannot meet these requirements. This creates a significant barrier to small business participation and may effectively preclude otherwise qualified small businesses from teaming on this requirement entirely. a) No, the subcontractor is not precluded from participating under this contract if it doesn't have an adequate accounting system, DCAA audit history, or forward pricing rate; however, they do need to provide a full labor rate build IAW L.4.2.3.9 and the supporting cost narrative identified in L.4.2.5 in order for the Government to perform its cost realism evaluation IAW M.4.2.6 and confirm the proposed direct labor rates are at or above the direct labor floor rates IAW M.4.2.7.

b) If the subcontractor does not have supporting data such as forward pricing rates (L.4.2.5.1.2.1) or provisional billing rates (L.4.2.5.1.2.2), then they are to provide the information identified in L.4.2.5.1.2.3 in order for the Government to perform its cost realism evaluation on the subcontractors proposed indirect rates.

c) The procedures under FAR 52.244-2 only become applicable after the contract is awarded; therefore, any requests for contracting officer consent related to FAR 52.244-2 would be determined post award.

This solicitation is for a Cost-Plus-Fixed-Fee (CPFF) requirement. To ensure a fair and equitable evaluation IAW Section M, the Government must perform a cost realism analysis on all proposals and confirm that the proposed direct labor rates are at or above the Government-provided Direct Labor Floor Rates. This requires full transparency into the proposed cost structure—including direct and indirect rates—for all prime and subcontractor efforts. Submitting proposals where the cost build-up is not visible would make it impossible to conduct this analysis and compare offers on a common basis. Therefore, for the purpose of this proposal submission, all subcontractors (regardless of subcontract type) are required to provide a full and complete labor build as required in L.4.2.3.9 and a supporting cost narrative for direct/indirect rates IAW L.4.2.5.1.

Composite Labor Rates 12

126 ATT 47

B.4 Section H.2.1 Substantive (a) Will Attachment 0047 be issued as a blank template with the final RFP, or will it be populated post-award by the Government based on the awardee's GFPM? (b) For proposal purposes, should offerors reference Attachment 0047 in their proposals as a placeholder, or is the GFPM (Attachment 0038) the operative document for communicating composite labor rates during the proposal phase? (c) Will the rates in Attachment 0047 represent a single composite rate blending all labor categories within a service type (e.g., one rate for all "Total Package Fielding" labor), or will separate ceiling rates be established by individual labor category? Sections B.4 and H.2.1 reference Attachment 0047 as the vehicle for incorporating awarded composite labor rates and fixed fee per hour into the contract. Attachment 0047 does not appear to be included in this draft RFP. a) Attachment 0047 will not be incorporated as a template in the Final RFP; however, it will be populated with the final composite labor rates and fixed fee per service, and incorporated into the award document.

b) Offerors do not need to reference Attachment 0047 in its proposal.

c) Yes, the rates in Attachment 0047 will represent a single composite rate blending all labor categories within a service type (e.g., one rate for all "Total Package Fielding" labor).

124 Section B.6, Section H.2.2, Section L.4.2.3, ATT 38 (GFPM Workbook) Substantive Please confirm: (a) Does the Government intend to permit offerors to propose different percentages for CONUS and OCONUS labor categories given the materially different cost bases and risk profiles involved? (b) If so, will the Government update the GFPM to release to include separate rate input cells for CONUS and OCONUS labor categories to accommodate differentiated rate proposals? The solicitation establishes materially different cost structures for CONUS and OCONUS labor categories, including higher direct labor rates, additional burdens such as DBA Insurance, Recruitment and Retention Incentives, Post Hardship Differential and Danger Pay, and a wider ceiling rate buffer of 20% for OCONUS versus 10% for CONUS (Section H.2.2). Given these differences in cost base and risk profile, an offeror may reasonably propose a different indirect rate and fixed fee for OCONUS labor than for CONUS labor, consistent with FAR 15.404-4. However, Attachment 0038 (GFPM) appears to contain a single input cell that is applied uniformly across both CONUS and OCONUS labor categories, preventing offerors from proposing differentiated rates by location. a) The Government does not intend to permit offerors to propose different percentages for CONUS and OCONUS labor categories. The solicitation already accounts for the difference in the OCONUS risk profile through other structural mechanisms. Specifically, Section H.2.2 provides a higher ceiling rate for OCONUS labor (not to exceed 120% of the proposed rate) compared to CONUS labor (not to exceed 110%). The Government considers this additional 10% ceiling flexibility to be the designated method for mitigating the contractor's cost risk associated with OCONUS performance.

Additionally, please be advised that the official RFP will be revised to simplify the pricing of Defense Base Act (DBA) insurance. DBA will be removed as a component of the fully burdened labor rate. Instead, offerors will be instructed to propose DBA as a separate, direct OCONUS cost. It will not be included in the total evaluated price for the purposes of proposal evaluation.

b) Based on the above, the GFPM will not be updated to accommodate differentiated rate proposals.

Could the USG clarify whether this requirement reflects LOE WDs and/or Completion CPFF WDs? Completion CPFF WDs typically obligate the contractor to deliver the specified end product, and labor hours used to perform the work are generally estimates rather than contractual ceilings. As such, a contractor may exceed estimated labor hours to achieve the required deliverable, provided performance remains within the estimated cost and funding limitations. This requirement reflects LOE work directives. For LOE WDs the contractor is required to stay within the awarded hours. For completion WDs, the contractor is required to stay within the funded cost.

For example, is the expectation to only provide on-call support like a phone call or is the expectation to have the FSR's available for hands-on support 24/7 in a bench strength capacity. Requesting clarity to ensure a shared understanding of scope and to reduce potential misinterpretation of requirements. As stated in C.11.1, FSR work schedules shall coincide with that of the associated Government personnel they are supporting. FSR schedules are event driven and required support will be outlined in the work directive. Typically, FSRs that are co-located with the unit will be required to provide hands-on support, as required 24/7. FSRs that are not co-located may be required to be available on-call by phone, 24/7 and provide hands on support within the designated response timeframe.

The reference to 24/7 support will be removed from Section C.8.9.2. C.11.1 will reflect the support will be outlined in the Work Directive.

C 27 C.9.8 Substantive This SOW section only lists the following MOS's: 91A, 91F, 91H, 91P, 91G, 91M, H9 Identifier." and "19C, 13F, 12B, 11B, 19D, 13B, 19K, 21B, 25U, J3 Identifier"

Does the USG intend on including additional MOS's to this requirement?

This contract will utilize composite labor rates, each corresponding to a distinct service as outlined in the "service" column of the GFPM Attachments (e.g., Field Service Representative (FSR), Deprocessing, MWO Installation, etc.).

WDs may include composite rates from one or more of the distinct services outlined in the "service" column of the GFPM attachments if needed.

The Past Performance Relevancy Rating Method is as follows:

Very Relevant-Present/past performance effort involved essentially the same scope and magnitude of effort and complexities this solicitation requires.

Relevant-Present/past performance effort involved similar scope and magnitude of effort and complexities this solicitation requires.

Somewhat Relevant-Present/past performance effort involved some of the scope and magnitude of effort and complexities this solicitation requires.

Not Relevant-Present/past performance effort involved little or none of the scope and magnitude of effort and complexities this solicitation requires.

The Past Performance Confidence Assessments Rating Method is:

Substantial Confidence-Based on the offeror’s recent/relevant performance record, the Government has a high expectation that the offeror will successfully perform the required effort.

Satisfactory Confidence-Based on the offeror’s recent/relevant performance record, the Government has a reasonable expectation that the offeror will successfully perform the required effort.

Neutral Confidence-No recent/relevant performance record is available or the offeror’s performance record is so sparse that no meaningful confidence assessment rating can be reasonably assigned. The offeror may not be evaluated favorably or unfavorably on the factor of past performance.

Limited Confidence-Based on the offeror’s recent/relevant performance record, the Government has a low expectation that the offeror will successfully perform the required effort.

No Confidence-Based on the offeror’s recent/relevant performance record, the Government has no expectation that the offeror will be able to successfully perform the required effort.

M 137 M.4.3 Critical What are the ratings for the Small Business Participation Factor? It is unclear if SBP will be Acceptable/Unacceptable or rated adjectivally. The Army is required to use the DoD Source Selection Procedures Small Business Rating Method, which is:

Outstanding-Proposal indicates an exceptional approach and understanding of the small business objectives.

Good-Proposal indicates a thorough approach and understanding of the small business objectives.

Acceptable-Proposal indicates an adequate approach and understanding of small business objectives.

Marginal-Proposal has not demonstrated an adequate approach and understanding of the small business objectives.

Unacceptable-Proposal does not meet small business objectives.

Complexity levels are defined as: (1) Minor MWO installation is defined as software updates or updates to platform(s) not requiring equipment beyond vehicle equipped tools, equivalent to military (-10) level; (2) Moderate MWO installation is defined as vehicle modifications including replacing, repairing, or removing brackets, wire assemblies, or components using tools or skill set beyond the operator's abilities, equivalent to military (-20) level; (3) High MWO installation is defined as removing multiple main assemblies from the platform to modify or alter the assemblies to a new configuration; drilling, cutting, welding, and/or grinding on the vehicle to apply the modification, equivalent military (-30 or higher) level."

Whatever complexity level MWO the offeror provides will be compared to the "high" definition from C.10. The closer an offeror gets, the more credit it will receive. For clarification, there is no threshold for complexity.

The Government cannot provide the expected volume distribution across these levels.