Solicitation Questions and Answers_Amendment 0001.pdf

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Attached to
Army Financial Improvement (AFI) Program Support Services Federal contract opportunity
Solicitation number
W91CRB-21-R-0049
Issued by
Department of the Army Materiel Command Army Contracting Command Aberdeen Proving Ground

About this file

This document is a Request for Proposal (RFP) issued by the U.S. Army Contracting Command - Aberdeen Proving Ground (ACC-APG) on behalf of the Assistant Secretary of the Army (Financial Management and Comptroller) (ASA(FM&C)) for Army Financial Improvement (AFI) Program support services. The RFP is a non-personal services requirement to provide the Army with professional federal accounting and auditing solutions and change management support to assist the Army in obtaining an unmodified audit opinion of its financial statements.

The resultant award will be a single award, indefinite delivery/indefinite quantity (IDIQ) contract with a maximum ceiling amount of $249,999,999.99 over a three (3) year ordering period. Task orders will be issued on a Firm Fixed Price (FFP) and/or Time and Materials (T&M) basis. The anticipated period of performance is February 2025 - February 2028, which includes a 90-day transition-in period. Offers are due no later than 10:00AM ET on 01 October 2024.

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Question # RFP Location (Section, Paragraph, Attachment)

Question/Clarification Government Response

1 What is the current contract number for this recompete? GS00F290CA Task Order W91CRB18F0238

2 PWS 1.10.2, p. 12-13

Would the Government please consider allowing Commercial experience to count for the labor categories? As written, only federal experience is allowed and this prevents the use of people with relevant experience in industries like financial statement audits over public companies, private companies accounting or internal audit divisions, etc.

Yes, the Government will consider commercial experience in lieu of federal financial management and federal accounting for the following roles: Manager, Senior Consultant and Consultant. For all other roles, the unique and complex environment in which the US Army operates requires deep familiarity and understanding of Federal specific financial management and accounting. Any other roles that did not require Federal specific financial management or accounting in the original PWS will remain the same.

3 PWS 1.10.2, p. 12 Will the Government allow for advanced degrees or certifications to replace one or more years of relevant experience? The Masters Degree requirement is highly restrictive when considering staffing an engagement of over 500 personnel.

No, the Government will not consider replacing Master Degree requirements for the three roles stated in the PWS (Program Manager, Technical Director, Senior Manager). The unique and complex environment in which the US Army operates requires both deep technical experience as well as formal education from accredited universities/colleges. Additionally, these roles do not comprise the majority of the projected staffing requirements.

4 Section M, Factor 2 - Past Performance, Table

The Government has defined Past Performance "relevance" in the Q&A using DoD Source Selection Procedures, which state that dollar amount will be considered. Given that this is the largest single award contract in the Federal Government, a requirement that past performance must be relevant for dollar amount would heavily favor the incumbent contractor, and restrict fair and open competition. Would the Government define "relevance" in the RFP and state that dollar value is not considered in order to promote increased competition?

Per the DoD Source Selection Guide "relevancy" is defined as: "as it pertains to past performance information, is a measure of the extent of similarity between the service/support effort, complexity, dollar value, contract type, and subcontract/teaming or other comparable attributes of past performance examples and the solicitation requirements; and a measure of the likelihood the past performance is an indicator of future performance."

The Government will not revise the definition of "relevancy." The Government considers all aspects of the relevancy definition when evaluating past performance.

Section L, Volume 2, Factor 1 - Technical, Section 2 - Key Personnel and Staffing Key Personnel FFP Tab

Bullet A on Page 134 states "for all positions designated as Key Personnel in Section 1.10.2…the offeror shall submit resumes addressing the PWS". Should the offeror use the number of key personnel based on Attachment J.4 or J.5?

The Offeror should use the number of key personnel on Attachment J.5 (Task Order 1 Price Model).

Section M - Evaluation Factors for Award

"EVALUATION CRITERIA/EVALUATION

APPROACH,

"Feasibility of Approach" p.145

Will the Government please remove the following statement in the evaluation criteria: "Ambiguities may result in an unacceptable rating. No assumptions will be made by the Government evaluators regarding areas not defined in the Offeror’s proposal?"

As written, this statement adds subjectivity into the Government's evaluation, as ambiguity/assumptions will have to be made by non-incumbent Offerors given the RFP's relative lack of program detail and the fact that non-incumbents do not have the on-the-ground knowledge of the program that the incumbent has.

In addition, please see a related question below regarding the provision of a reading room.

The Government will not remove this statement. This statement refers to the Government evaluators. Evaluators will not make assumptions regarding areas not defined (ambiguities) in the Offeror's proposal. As stated in Section M, The Government's evaluation of the Offeror's proposal will be limited to information provided within proposals submitted, with the exception of Price, Past Performance, and Small Business Participation, where data extrinsic to the Offeror's proposals may be considered.

Section C - Descriptions and Specifications

PERFORMANCE WORK STATEMENT, 1.10.2

Requirements by Labor Category p.12-13

Will the Government broaden the key personnel language requiring experience unique to Army in financial management (FM), accounting, and audit practices to instead require that experience from anywhere in the Federal government. (i.e., the Technical Director Key Personnel requirement in section 1.10.2 of the PWS)? This requirement not only limits competition to the incumbent, but also negates the relevant and proven successes achieved outside of Army (i.e., OUSD(C), sister Services, and/or other Federal agencies that have achieved a clean audit opinion). Experience from outside the Army is not only relevant but needed given the Army's recent track record of frequently requesting audit remediation solutions that have achieved proven, measurable results at the other Services.

No, the PWS currently requires "federal financial management and federal accounting experience" for roles designated as key personnel. The Government has removed the word "Army" from the Technical Director labor category description.

Section L - Instructions, Conditions and Notices to Bidders

"PROPOSAL CONTENT REQUIREMENTS,

Volume 2 - Factor 1 – Technical

Section 1 – Technical Approach" p.133-134

Given that the Army has not yet resolved the 14 Issues outlined in Section L, would the Army consider requiring vendors to provide proof of successful implementation of their proposed solutions to better assess adequacy and feasibility? (e.g. FBWT or RP material weakness downgrades by other Services or a remediation vendor that has supported an agency achieving an unmodified opinion)

No, the Government will not consider adding language requiring proof of successful implementation of proposed solutions. However, offerors are able to demonstrate how a proposed approach has been successful in the past in both their past performance and technical approach submissions to demonstrate successful capabilities.

Section M - Evaluation Factors for Award

EVALUATION CRITERIA/EVALUATION

APPROACH

p.144

Can the government provide more information on how it plans to assess the feasibility of offerors proposed approaches? Unless the Source Selection team has significant experience from outside the Army, they may have difficulty assessing the likelihood that "end results" are "achievable" or that the offerors can be "expected to be able to successfully complete... technical requirements within the required schedule" given the incumbent vendors lack of progress over the last decade.

Absent an objective framework for evaluation, what basis do evaluators have to judge this criterion beyond alignment with current work, which would be "feasible" by definition since the Army has presumably already approved it?

The Government will evaluate proposals in accordance with the stated evaluation criteria in sections L & M. Offerors are responsible for providing a well-written proposal that demonstrates their ability to successfully meet the requirements.

Section M - Evaluation Factors for Award

EVALUATION CRITERIA/EVALUATION

APPROACH

p.144

Can the government provide more information on how it plans to assess the adequacy of offerors proposed approaches? i.e. How can an offerors "methods and approach have... completely considered, defined, and satisfied the requirements specified in the RFP"? By definition, "complete" supersedes "adequate" so the assessment language seems to be saying that the government will determine whether (a binary, yes/no question) an offerors proposed approaches "completely considered, defined, and satisfied the requirements specified in the RFP". A de facto pass/fail criterion to completely address solicitation requirements is heavily biased towards the incumbent. The government should consider both adjusting the evaluation language to accommodate more transparent scoring and providing more information to industry to be able to respond to Army's requirements on a more level playing field with the incumbent.

The Government will evaluate proposals in accordance with the stated evaluation criteria in sections L & M. Offerors are responsible for providing a well-written proposal that demonstrates their ability to successfully meet the requirements.

Section M - Evaluation Factors for Award

EVALUATION CRITERIA/EVALUATION

APPROACH, Factor 1 – Technical p.145

Can the government provide more context on the decision to explicitly avoid technical criteria or a proposed staffing and pricing approach that incorporates innovative technologies, such as Generative artificial intelligence (AI)? Allowing industry to include such solutions and innovations could enhance operational efficiency, reduce costs, and accelerate progress towards a clean audit opinion in contrast.

The prescribed level of effort for the base contract award, was established to 1) set labor rates for labor categories for each year of the ordering period and 2) support the contract ceiling. Offerors shall not deviate from the prescribed LOE.

Offerors are encouraged to propose innovative solutions in their technical proposals. The use of artificial intelligence and other innovative solutions is not prohibited in any sections of the proposal. Innovative solutions may--if evaluated as strengths and demonstrates a benefit to the Government--result in a higher technical rating. Offerors may propose innovative approaches that could result in technical, schedule or cost savings; offerors are encouraged to document the possible benefits to the Government.

Section L - Instructions, Conditions and Notices to Bidders

"PROPOSAL CONTENT REQUIREMENTS,

Volume 2 - Factor 1 – Technical Section 1 – Technical Approach

Evaluation Factors for Award

BASIS FOR AWARD"

Section M - Evaluation Factors for Award p.133-134 p.144

Given the volume of required elements and the limited page count, will the Government please provide more specificity surrounding how it will weight the three subfactors within Factor 1 relative to one another in its evaluation of Factor 1 - Technical?

Factor 1 will receive one overall rating in accordance with Section M of the solicitation. The Offeror shall address all 3 sections (Technical Approach, Key Personnel & Staffing, and Transition Plan) within their Technical Proposal. The Offeror's proposal will be evaluated for the extent to which the Offeror's Technical proposal will result in successful performance of the requirements of the solicitation.

Section C - Descriptions and Specifications

PERFORMANCE WORK STATEMENT, 1.18

Organizational Conflict of Interest p.15-16

Regarding Section 1.18 Organizational Conflict of Interest (OCI), will the data provided regarding procurement sensitive and source selection information be anonymized to allow for greater objectivity?

The Procuring Contracting Officer (PCO) will assess the OCI mitigation Plan.

Procurement sensitive and source selection information will not be disclosed to any unauthorized individuals. The PCO will ensure that procedures exist to safeguard source selection information and contractor proposal information.

Section L - Instructions, Conditions and Notices to Bidders

"PROPOSAL CONTENT REQUIREMENTS,

Volume 1 – Executive Summary" p.132

The Government indicates that it will "evaluate the submittals considering in-house knowledge as to the company's program support“ when evaluating OCI Identification and Risk Mitigation Plans.

The inclusion of this statement introduces subjectivity into the assessment of the OCI Identification and Risk Mitigation Plan. Will the Government instead use an approach with the transparency and objectivity necessary for a fair evaluation of both Prime and subcontractor active, perceived, or potential OCI? We recommend the Government replace this phrase ["The Offeror shall identify, at a minimum, all current contracts or financial interests that might be affected by the performance of the PWS."] with this phrase ["The Offeror shall identify, at a minimum, all current contracts or financial interests whose requirements relate to non-public information to include budgetary data, procurement sensitive information, or the evaluation and/recommendations of other service or product/system acquisition of the Army or Department of Defense (DoD)."] in the Instructions in order to achieve a transparent, objective, and fair evaluation of Offerors' OCI submissions.

If the Government keeps this statement as worded, will the Government please clarify how it will gain appropriate "in-house knowledge" of both Prime Offerors' and their subcontractors' active, perceived, or potential OCI in order to evaluate all OCI Identification and Risk Mitigation Plan submissions fairly?

The Government will not make any changes to the solicitation as recommended by this question. The PCO will consider each OCI Identification and Risk Mitigation Plan, along with the particular facts to determine whether the OCI can be mitigated. The PCO will examine the particular facts of the contracting situation and the nature of the proposed contract, and exercise common sense, good judgment, and sound discretion in deciding whether a significant OCI exists and determining the appropriate means for resolving any significant OCI that has been identified.

Section L - Instructions, Conditions and Notices to Bidders

"PROPOSAL CONTENT REQUIREMENTS,

Volume 1 – Executive Summary" p.132

Will the Government please confirm that Offerors should submit their OCI Risk Mitigation Plans as a standalone document, separate from the remainder of Volume 1 contents, so that it may easily be incorporated into any contract awarded as a result of this procurement?

Per section L, the OCI Risk Mitigation Plan shall be included in Volume 1 - Executive Summary of the Offeror's proposal.

For companies looking for teaming arrangements, please utilize the Interested Vendors List on the sam.gov for this solicitation. Information from the Contracting Office

Section L - Instructions, Conditions and Notices to Bidders

Section M - Evaluation Factors for Award

"PROPOSAL CONTENT REQUIREMENTS,

Volume 2 - Factor 1 – Technical p.133-136

Section M, EVALUATION

CRITERIA/EVALUATION APPROACH,

Factor 1 – Technical

p. 145-146

Will the Government please increase the page limit of Volume 2, Factor 1 - Technical to 50 pages in order to allow Offerors to adequately address the Factor 2 Instructions and Evaluation Criteria? To successfully “present the information in sufficient detail for effective evaluation of the Offeror’s proposal against the evaluation criteria" (as cited in Section L), Offerors require adequate space to address: 1) an understanding of the Army's audit readiness situation and all PWS requirements; 2) a Technical Approach including approaches to 14 audit-related issues (bullets A-N); 3) a Staffing Approach that includes hiring and retention methods/procedures, a Management Plan, a Training Plan, and an approach to ensuring adequate personnel security qualifications; 4) a Transition Plan that includes both Transition-In and Transition-Out Plans; and 5) all nine (9) detailed, distinct evaluation criteria.

The Government has increased the page limit of Volume 2, Factor 1 - Technical to 50 pages. Section L has been updated to reflect this change.

Section L - Instructions, Conditions and Notices to Bidders

PROPOSAL SUBMISSION REQUIREMENTS,

#4 p.129

The Government requires offerors to include a Summary Section in each volume. Will the Government confirm that the Summary Section is outside of the page limit for Volume 2 in order to give Offerors the maximum number of pages within the Volume's page limit to adequately address the Factor 2 Instructions and Evaluation Criteria? To successfully “present the information in sufficient detail for effective evaluation of the Offeror’s proposal against the evaluation criteria" (as cited in Section L), Offerors require adequate space to address: 1) an understanding of the Army's audit readiness situation and all PWS requirements; 2) a Technical Approach including approaches to 14 audit-related issues (bullets A-N); 3) a Staffing Approach that includes hiring and retention methods/procedures, a Management Plan, a Training Plan, and an approach to ensuring adequate personnel security qualifications; 4) a Transition Plan that includes both Transition-In and Transition- Out Plans; and 5) all nine (9) detailed, distinct evaluation criteria.

The summary section is included in the page limit for Volume 2. The Government has increased the page limit of Volume 2, Factor 1 - Technical to 50 pages. Section L has been updated to reflect this change.

Section C - Descriptions and Specifications

PERFORMANCE WORK STATEMENT, 1.10.2

Requirements by Labor Category p.13

Can the Government provide more context on the decision to add the Technical Director LCAT to those LCATs provided for industry feedback in the draft RFP? i.e. What business or mission requirement changed between May and August that prompted a new need for 14 key personnel who “Shall be the senior most technical executive on the contract” with Masters degrees, both internal and external audit experience, FM certifications, and Army-specific FM/accounting/audit practices? That degree of change along with dozens of other additional key personnel compared to the draft suggests that factors are in play that should be considered in developing all parts of offeror's responses.

Given the expansive technical requirements and relatively low page limit, all offerors other than the incumbent are placed at a severe disadvantage in knowing what points to emphasize or solutions to highlight absent more information. Since the PWS is otherwise mostly unchanged between draft and final and there was nothing apparent in the Q&A that prompted such an addition, any prospective competitor to the incumbent needs more information to be responsive to whatever circumstances prompted such a drastic change in the Government’s staffing needs. This clearly favors the incumbent and puts the rest of industry at an unfair disadvantage.

Yes, the Government restructured the LCAT's to broaden the range of support possible to successfully execute the objectives in the PWS by more clearly delineating qualifications and experience. The Technical Director LCAT was modified to provide singular oversight of the vendor's work. The Government believes that broadening the LCAT options actually increases offeror's abilities to provide more dynamic staffing solutions to their proposals.

The LOE for TO1 was updated to reflect only 1 Technical Director (see other changes for Program Manager and Team Lead). The LOE for the base IDIQ will not be updated as it was established to 1) set labor rates for labor categories per year and 2) support the contract ceiling. The hours associated with labor categories in the base IDIQ price model are not indicative of the anticipated LOE, the anticipated LOE for the first year is prescribed in TO1.

Section M - Evaluation Factors for Award

EVALUATION CRITERIA/EVALUATION

APPROACH, Factor 1 – Technical p.145

Will the Government confirm that the 7th bullet in the list of 9 bullets in the "Factor 1 – Technical" evaluation criteria is the only bullet that will be used to evaluate Key Personnel Resumes?

The predominance of the Key Personnel Resumes will be evaluated in accordance with bullet 7 in Section M - Factor 1 - Technical. However there may be crossover with other bullets in this section.

Section C - Descriptions and Specifications

PERFORMANCE WORK STATEMENT, 1.6.7

Personnel Security Clearance Requirements p.10

Will the Government please estimate the quantity of resources required to have TS/SCI clearances?

When the time comes for TS/SCI work, there would be ample notification time for resources to be acquired. At this time there is no forecast for TS/SCI resources.

Section L - Instructions, Conditions and Notices to Bidders

Section M - Evaluation Factors for Award

"PROPOSAL CONTENT REQUIREMENTS,

Volume 2 - Factor 1 – Technical, Section 2 - Key Personnel and Staffing p.135

EVALUATION CRITERIA/EVALUATION

APPROACH,

Factor 1 – Technical p.145

Will the Government please clarify how it will evaluate elements B, C, E, and F of Section L, Section 2 - Staffing requirements (see below) in order to guarantee the transparency and objectivity necessary for a fair evaluation? There is currently no language in the Factor 1 evaluation criteria that clearly aligns with these elements.

RFP Requirement:

B. Identify methods/procedures in hiring and retention of qualified personnel. PWS 1.10.

C. Provide an organizational structure that is aligned with the technical specifications of the PWS, to include adequate quantities of personnel and labor categories. The organizational structure shall identify how Key Personnel fit into the overall organization and identify the proposed responsibilities for each Key Personnel, PWS 1.10. The organizational structure shall be submitted in Microsoft Office Excel unprotected format and viewable in Microsoft Excel versions 2016 and later and shall contain the following information: a. Position Title, i. Labor Category, ii. PWS reference, iii. Hours aligned to period of performance for this position.

E. The Offeror shall submit a plan that successfully demonstrates how all personnel will maintain required certifications and how personnel will be kept current on changing regulations and procedures.

F. The Offeror shall demonstrate their approach to ensure that General Certification from offerors and subcontractors’ security officer(s) that all proposed personnel possess the required security clearances as specified in PWS Section 1.6.7 and is verified in Defense Information System for Security (DISS).

Bullet 8 in Section M - Factor 1 - Technical, covers Section L Key Personnel and Staffing requirements B-F. Section M bullet 8 has been updated to read: "The extent to which the proposal demonstrates a successful staffing approach that clearly demonstrates sufficient controls for successfully managing the entire workforce, alignment of personnel with technical specification, the ability to recruit and replace employees with equivalent qualifications and security clearances, and how quickly replacements can be on-boarded."

Section M - Evaluation Factors for Award

EVALUATION CRITERIA/EVALUATION

APPROACH, Factor 1 – Technical p.145

Will the Government confirm that the 8th bullet in the list of 9 bullets in the "Factor 1 – Technical" evaluation criteria (see criteria below) is the only bullet that will be used to evaluate the Staffing section (excluding KP resumes)?

Evaluation Criteria (8th bullet): "The extent to which the proposal provides a detailed Management Plan that clearly demonstrates sufficient controls for successfully managing the entire workforce, the ability to recruit and replace employees with equivalent qualifications, and how quickly replacements can be on-boarded."

The predominance of the staffing section (excluding the Key personnel resumes) will be evaluated in accordance with bullet 8 in Section M - Factor 1 - Technical.

However there may be crossover with other bullets in this section.

Section L - Instructions, Conditions and Notices to Bidders

PROPOSAL CONTENT REQUIREMENTS,

Volume 2 - Factor 1 – Technical, Section 2 –

Key Personnel and Staffing - C.

p.135

Will the Government clarify to what "technical specifications of the PWS" Offerors must align our organizational structures? As written, the lack of clarity in this requirement grants the incumbent contractor a competitive advantage over non-incumbents, as the incumbent is the only bidder who has the Army's historical level of effort, skill mix, alignment of personnel, and current challenges and priorities as additional context to inform their alignment to PWS tasks to respond to requirements adequately.

RFP Requirement: "Provide an organizational structure that is aligned with the technical specifications of the PWS, to include adequate quantities of personnel and labor categories."

The Government will provide it's current Government organizational structure to provide context.

Section L - Instructions, Conditions and Notices to Bidders

PROPOSAL CONTENT REQUIREMENTS,

Volume 2 - Factor 1 – Technical, Section 2 –

Key Personnel and Staffing - C.

p.135

Will the Government please provide the organizational structure of the current contract as part of a reading room associated with this solicitation? As written, the lack of detail in the organizational structure requirements grants the incumbent contractor a competitive advantage over non-incumbents, as the incumbent is the only bidder who has the historical level of effort, skill mix, and alignment of personnel to PWS tasks to respond to requirements adequately.

RFP Requirement: "C. Provide an organizational structure that is aligned with the technical specifications of the PWS, to include adequate quantities of personnel and labor categories. The organizational structure shall identify how Key Personnel fit into the overall organization and identify the proposed responsibilities for each Key Personnel, PWS 1.10. The organizational structure shall be submitted in Microsoft Office Excel unprotected format and viewable in Microsoft Excel versions 2016 and later and shall contain the following information: a. Position Title, i. Labor Category, ii.

PWS reference, iii. Hours aligned to period of performance for this position."

The Government will provide it's current Government organizational structure to provide context.

Section L - Instructions, Conditions and Notices to Bidders

PROPOSAL CONTENT REQUIREMENTS

Volume 2 - Factor 1 – Technical Section 2 –

Key Personnel and Staffing - C.

p.134

Does the Government have a preferred Microsoft Excel format or template for submission of organizational structure beyond the requirements desired in Paragraph C? If so, will the Government make this available to offerors?

The Government does not have a preferred Microsoft Excel format or template for the submission of the Organizational Structure.

Section L - Instructions, Conditions and Notices to Bidders

PROPOSAL CONTENT REQUIREMENTS

Volume 2 - Factor 1 – Technical Section 2 –

Key Personnel and Staffing - C.

p.134

Will the Government please confirm whether Offerors should include both key personnel and non-key personnel in our organizational structure?

Yes, offerors are encouraged to provide the level of detail they think are appropriate to support their approach. However, offeror's are only required to provide specific names, resumes and letters of intent for key personnel.

Section M - Evaluation Factors for Award

EVALUATION CRITERIA/EVALUATION

APPROACH, Factor 1 – Technical p.145

Will the Government confirm that the 9th bullet in the list of 9 bullets in the "Factor 1 – Technical" evaluation criteria (see criteria below) is the only bullet in the Factor 1 evaluation criteria that will be used to evaluate the Section 3 - Transition Plan?

Evaluation Criteria (9th bullet): "The extent to which the proposal provides a detailed Transition Plan that demonstrates an adequate approach with minimal disruption to ongoing operations during transition-in/out activities."

The predominance of the Transition Plan will be evaluated in accordance with bullet 9 in Section M - Factor 1 - Technical. However there may be crossover with other bullets in this section.

Section L - Instructions, Conditions and Notices to Bidders

PROPOSAL CONTENT REQUIREMENTS,

Volume 2 - Factor 1 – Technical, Section 3 –

Transition Plans p.135

In order to appropriately address the Transition-In requirement of this RFP, will the Government provide the current incumbent's Transition-Out Plan as part of a reading room associated with this solicitation?

The Government will not provide the incumbent's transition-out plan.

Section L - Instructions, Conditions and Notices to Bidders

PROPOSAL CONTENT REQUIREMENTS,

Volume 2 - Factor 1 – Technical, Section 3 –

Transition Plans p.135

Will the Government please confirm that the awarded Offeror will be required to transition a total of 675 FTEs (assuming the assertion that 1434 hours is the correct basis of a Full Time Equivalent for the 9-month Base Period) onto a new contract by the 45th day of the 90-day transition period?

Per solicitation Attachment J.5 (updated) - Task Order 1 Price Model, the Offeror will be required to transition a total of 803.38 FTEs onto a new contract by the 45th day of the 90-day transition in period. All Key Personnel (19 FTEs) shall begin performance on the first day of the transition-in period and all remaining non-key employees (784.38 FTEs) shall begin performance no later than the 45th day of the 90-day transition-in period. Offerors shall propose their own transition-in LOE. One

(1) FTE for 12 months equals 1,912 hours (12 months).

Section L - Instructions, Conditions and Notices to Bidders

PROPOSAL CONTENT REQUIREMENTS

Volume 2 - Factor 1 – Technical Section 3 –

Transition Plans p.135

As it is the Government's intent to compete a multi-award IDIQ follow-on procurement to this one, will the Government consider requiring Offerors' to submit a detailed Transition-Out Plan by Task Area and/or Scenario for evaluation given that subsets of the single award scope would presumably be transitioned to task orders on the multi-award vehicle in a staggered manner?

No, Offerors shall submit their transition-out plan as if 100% of the work is being transitioned at one time, not by Task Area/Scenario.

Section L - Instructions, Conditions and Notices to Bidders

PROPOSAL CONTENT REQUIREMENTS,

Volume 3 - Factor 2 – Past Performance p.136

Will the Government confirm that "alternative resources" it could use to "gather past performance information" include only PPQs and CPARs? If "alternative resources" includes resources in addition to PPQs and CPARs, will the Government please clarify what those resources are, in order to confirm the transparency and objectivity necessary for a fair evaluation?

RFP Requirement: "the Government reserves the right to use alternative resources to gather past performance information. the Government may independently obtain information from other sources, which may be used to evaluate past performance against the requirements set forth in the solicitation." "reserves the right to use alternative resources to gather past performance information" the Government is limited to PPQs and CPARs? If not, how will "alternative resources" be documented & evaluated by the Government?

Section M of the solicitation states "The Government may consider a wide array of information from a variety of sources. The Government may use data provided by the Offeror in its proposal and data obtained from other sources, including data in Government files or data obtained through interviews with personnel familiar with the contractor and their current and past performance. The Government may evaluate third party references provided as to each Offerors and major subcontractor’s relevant and recent efforts, to verify the probability of successful accomplishment of the required effort."

The DoD Source Selection Guide, sources of Past Performance Information provides further explanation as follows: "Past performance information provided by the offeror, as solicited; Past performance information obtained from questionnaires tailored to the circumstances of the acquisition; and Past performance information obtained from any other sources available to the Government, to include, but not limited to, CPARS, FAPIIS, eSRS, or other databases, the Defense Contract Management Agency, and interviews with Program Managers, Contracting Officers, and Fee Determining Officials."

Section L - Instructions, Conditions and Notices to Bidders

PROPOSAL CONTENT REQUIREMENTS,

Volume 3 - Factor 2 – Past Performance p.137

If the offeror is including Past Performance for an IDIQ, will the Government please confirm that items e-j (listed below) should be provided only at the IDIQ level, rather than at the Task Order level?

RFP Requirements:

e. Contract Number and, in the case of Indefinite Delivery type contracts, GSA contracts, and Blanket Purchase Agreements, include Delivery Order Numbers also.

f. Contract Type (specific type such as Time and Materials (T&M), Firm Fixed Price (FFP) or Cost Plus Fixed Fee (CPFF)). In the case of Indefinite Delivery contracts, indicate specific type (Requirements, Definite Quantity, and Indefinite Quantity) and secondary contract type (T&M, FFP, CPFF, etc.).

g. Awarded price/cost.

h. Final or projected final price/cost.

i. Original delivery schedule, including dates of start and completion of work.

j. Final or projected final delivery schedule, including dates of start and completion of work.

Offerors shall provide the requested information for both the IDIQ level and the Task Order level as one Past Performance submission, ensuring a full picture is presented for that specific contract action.

Section L - Instructions, Conditions and Notices to Bidders

PROPOSAL CONTENT REQUIREMENTS,

Volume 3 - Factor 2 – Past Performance p.139

Volume 3 - Factor 2 – Past Performance: Will the Government remove the requirement for Past Performance to be prime work only? If this requirement is not removed, it could preclude qualified vendors with a mix of proven solutions and skills from teaming in a way that could be advantageous for the Army.

The Government will not remove this requirement. Per section L Factor 2, past performance examples should be where the Offeror or major subcontractor performed the work as the prime contractor.

Attachments J.4 and J.5 "Key Personnel FFP" sheet - column D

"Non-Key T&M" sheet - column D "Transition-In Price FFP" sheet, column E

Attachments J.4 and J.5 ask for each line to be designated as Prime or Sub, using "P" or "S." Given that different subs will have different rates within the same PWS Labor Category, does the Government need to know the name of each subcontractor that corresponds to each line item and rate? If so, will the Government provide additional clarification as to how the Prime / Sub column should be completed? For example, should Offerors fill in "S - <sub name>" ?

Attachment J.4 and J.5 have been updated to remove the Prime or Sub column. If the particular individual category is to be performed by more than one entity and the subcontractors fully-loaded rates (including prime burdens & profit/fee) are equal to or less than the proposed 'ceiling' rates submitted by the offeror for each LCAT, no additional steps are required. If the subcontractor rates are higher, then the Offeror will be required to insert additional row(s) under the labor category to provide additional information.

Attachments J.4 and J.5 "Key Personnel FFP" sheet - column E

"Non-Key T&M" sheet - column E "Transition-In Price FFP" sheet, column F

Attachments J.4 and J.5 ask for each line to be designated as the employee status with either a "C," "N," or "I." Given the large number of FTEs per labor category, will the Government confirm that each row may have multiple Status designations?

The Government confirms that each row may have multiple status designations.

Where there are a combination of personnel types (statuses) within the required FTE quantities, column E of the Price Proposal Model shall be completed or footnoted as, for example: "4 C and 4 N". The employee status designation requirement has been removed for non-key personnel in both attachment J.4 and J.5.

Attachment J.4 "Key Personnel FFP" sheet - column E

"Non-Key T&M" sheet - column E "Transition-In Price FFP" sheet, column F

Will the Government clarify why the Status column is necessary in the Attachment J.4 - Base IDIQ Price Model since presumably he Base IDIQ price is presumably for evaluation purposes and to generate the IDIQ ceiling amount?

The status column allows the Government to understand whether the proposed personnel is a current employee or a new hire and indicates when Letters of Intent are required. The status column has been removed for non-key personnel in both J.4 and J.5 attachments.

Attachment J.4 "Key Personnel FFP" sheet - column E

"Non-Key T&M" sheet - column E "Transition-In Price FFP" sheet, column F

Will the Government explain how the employee status ("Current employee" "New Hire," or "Incumbent") will be used in the IDIQ evaluation? On its face, by having a separate classification and identification of incumbent staff, this appears to provide an advantage to the incumbent.

Considering that the IDIQ pricing is presumably just an evaluation model to develop an overall IDIQ-level price, and the hours are not guaranteed to be ordered, there does not appear to be any logical reason to identify an employee status, when the employees being priced are just theoretical. We would appreciate if the Government would explain why this information is being sought in Attachment J.4, how it will be used during the IDIQ price evaluation, and how it does not provide an unfair advantage to the incumbent.

The status column allows the Government to understand whether the proposed personnel is a current employee or a new hire and indicates when Letters of Intent are required. The incumbent designation has been removed. The status column has been removed for non-key personnel in both J.4 and J.5 attachments.

38 Attachment J.4 Attachment J.5

Will the Government please clarify what number of hours Offerors should use to calculate an annual Full Time Equivalent? Both Attachments J.4 and J.5 have incorrect/inconsistent formulas to calculate an annual FTE given that the hours provided are labeled as covering a 9-month Period of Performance.

Per Attachment J.4 and J.5 an annual FTE equals 1,912 hours. The Task Order Price Model hours are based on a full level of effort after the transition-in is completed, i.e. 1434 hours (9 months). Offerors shall propose their own LOE for the 90-day transition-in.

39 Attachment J.4 Both Attachments J.4 and J.5 have sheets for "Key Personnel FFP," "Non-Key T&M," and "Transition- In Price FFP." Will the Government please clarify that Attachment J.4 (Base IDIQ Price Model) will be used for generating an IDIQ ceiling price and for proposal evaluation purposes only?

The Government confirms that Attachment J.4 will be used for generating an IDIQ ceiling price and to establish labor rates over the life of the contract. Per Section M, the total evaluated price (TEP) to be used in the award determination will be the total of ALL Section B CLINs identified within the submitted Base IDIQ Price Model, with the exception of the transition-in CLIN. The proposed price for task order 1 (Task Order 1 Price Model) will be evaluated for price fairness and reasonableness in accordance with FAR 15.404-1, and consistency with the Government-prescribed TO1 skill mix and LOE, normalized travel/ODCs, as well as consistency with the offeror's proposed rates contained in the submitted Base IDIQ Price Model.

40 Attachment J.5

Both Attachments J.4 and J.5 have sheets for "Key Personnel FFP," "Non-Key T&M," and "Transition- In Price FFP." Will the Government please clarify that Attachment J.5 (TO 1 Price Model) provides the intended delivery model and the labor mix that Offerors should use to inform our organizational structures and determine the number of key personnel resumes to submit in our proposals?

The Government confirms that Attachment J.5 (Task Order 1 Price Model) provides the intended delivery model and the labor mix that Offerors should use to inform the organizational structures and determine the number of key personnel resumes to submit in their proposals.

41 Attachment J.4 Attachment J.5

Will the Government please confirm that 1434 hours is the appropriate number of hours Offerors should use to calculate a Full Time Equivalent for the 9-month Base Period for both the Base IDIQ and TO1?

Yes, 1434 hours is the FTE equivalent for the 9-month full performance section of Task Order 1. (1912/12*9=1434)

Section M - Evaluation Factors for Award

Attachment J.4 "Transition-In Price FFP" sheet, column E

Will the Government clarify what scope offerors should price for the Transition In requested within Attachment J.4 - Base IDIQ Price Model? Given the IDIQ pricing is for evaluation purposes only, and the Transition In is not included in the Price Evaluation, asking offerors to estimate and price a Transition In for which there is no scope appears to have no purpose.

Will the Government consider removing the Transition In from the IDIQ Price Model, and only requiring it of the Task Order 1 Price Model?

Or, will the Government consider providing Transition In hours to Offerors for the IDIQ Price Model only, since the IDIQ price is only for IDIQ ceiling evaluation purposes only?

The CLIN structure on the base IDIQ has to be established for the Task Order to be issued. As there is a separate CLIN on the Task Order for transition-in there needs to be a corresponding CLIN on the base IDIQ. Offerors shall propose the labor categories and hours they feel are required for the 90-day transition-in period. Key Personnel shall begin on the first day of performance and remaining non-key employees shall be fully transitioned in by the 45th day of performance. The information for transition-in shall be the same on both attachments J.4 and J.5.

Attachments J.4 and J.5 "Key Personnel FFP" sheet - column C

"Non-Key T&M" sheet - column C "Transition-In Price FFP" sheet, column C

Attachments J.4 and J.5 ask for the Contractors Title/Position. Will the Government explain how this information will be used during the evaluation process and contract performance? Will the Contractor's Title/Position be incorporated into any resulting contract?

This column has been removed from both attachment J.4 and J.5. The Governments original intent was to allow offerors a location to link possible GSA schedules (or other contract vehicles) with differently named labor categories to the labor rates associated on this solicitation to assist with a fair and reasonable determination.

Section L - Instructions, Conditions and Notices to Bidders

PROPOSAL CONTENT REQUIREMENTS,

Volume 5 - Factor 4 – Cost/Price p.139

Will the Government consider adding a Professional Employee Compensation Plan requirement for the Prime and all subcontractors, to ensure that salaries and compensation levels under this long-standing program are not harmed during this recompete?

The Government will not add a requirement for Total Compensation Plans. FAR 52.222-46 is not required for commercial procurements.

Section L - Instructions, Conditions and Notices to Bidders

PROPOSAL CONTENT REQUIREMENTS,

Volume 5 - Factor 4 – Cost/Price p.140

The RFP states that each Offerors and its subcontractors shall provide "whatever information is necessary to help the Government understand why the proposed prices are fair and reasonable in the Price Narrative. Each Offeror's cost/price proposal shall contain sufficient quantitative and narrative documentation to adequately support and explain the prices proposed, to include subcontractor proposed costs."

The above referenced text establishes a requirement, but does not provide enough specificity as to what the Government will find to be acceptable. This creates a situation in which the Offeror is unclear as to the standard to which they will provide an acceptable response. Further, as a commercial items procurement, the FAR does not provide any guidance applicable to Offerors, instead placing the responsibility of a price analysis on the Government evaluators. Per FAR 12, commercial pricing is fair and reasonable, and it is through the comparison of prices received that the Government should be determining the most reasonable price for the requirement. No additional substantiating information should be necessary.

Will the Government provide more specific requirements as to what information and analysis offerors are required to provide in order to be responsive to this requirement?

Per Section L, Volume 5 - Factor 4 - Cost/Price, this volume shall include pricing documentation and a complete detailed cost/price narrative with supporting information. The prime contractor shall conduct appropriate price analyses to establish the reasonableness of proposed subcontractor(s) prices and include the results of these analyses in the price proposal (unless proprietary data will not be shared between the prime and sub). Each offeror and its subcontractor(s) shall provide whatever information necessary to help the Government understand why the proposed prices are fair and reasonable in the Price Narrative. Each offeror's cost/price proposal shall contain sufficient quantitative and narrative documentation to adequately support and explain the prices proposed, to include subcontractor proposed costs. Offerors shall include all requested information/documentation listed in Section L, Volume 5 - Factor 4 - Cost/Price (see requirement #s 1-11) within their price proposal in addition to the completed price models. The Government strongly encourages inclusion of supporting documentation to substantiate the fairness and reasonableness of the proposed cost/prices.

Section L - Instructions, Conditions and Notices to Bidders

PROPOSAL CONTENT REQUIREMENTS,

Volume 5 - Factor 4 – Cost/Price p.141

The RFP states, "The accounting system requirements are also applicable to subcontractors. If the subcontractor's accounting system is not adequate for the contract type, the prime offeror should consider a fixed priced award to the sub."

The requirement for subcontractors to have a DCAA/DCMA approved accounting system will prevent the use of many small businesses that are otherwise highly capable of performing this scope of work. This may harm the Contractor's and Government's mutual goals to use small businesses of various socioeconomic designations.

A fixed price subcontract is not feasible for a T&M CLIN because the Offeror can only invoice on the basis of hours worked and charged, and a fixed price subcontract will not include hours.

Will the Government confirm that subcontractors without a DCAA or DCMA-approved accounting system only needs to demonstrate evidence of a timekeeping system appropriate for a fixed-labor-hour-rate subcontract, or provide a letter completed by a CPA firm stating that their system is adequate for tracking time under a Labor Hour subcontract?

FAR 16.104(i) requires offerors to be confirmed to possess an accounting system adequate for a Time and Materials (T&M) contract. Specifically it states "Adequacy of the contractor's accounting system. Before agreeing on a contract type other than firm-fixed-price, the contracting officer shall ensure that the contractor’s accounting system will permit timely development of all necessary cost data in the form required by the proposed contract type". An adequate accounting system does not necessarily mean approved accounting system. Offerors may demonstrate this accounting system adequacy through a signed assessment either from the offeror's cognizant accounting officer(s) or from the DCAA or the DCMA or by any other means. The accounting system requirements are also applicable to subcontractors. If the subcontractor's accounting system is not adequate for the contract type, the prime offeror should consider a fixed price award to the sub.

Section C - Descriptions and Specifications

PERFORMANCE WORK STATEMENT, 1.6.5

Place of Performance p.9

The RFP mentions OCONUS travel. Will the Government provide a list of the OCONUS countries? If so, what are they and do they have a Status of Forces Agreement?

No, the Government can not provide a specific list of OCONUS locations, however, offeror's may be expected to travel to Army and DoD locations around the world in support of the PWS objectives. The specific locations will be determined by need, funding, materiality and external audit requirements. If a OCONUS travel location is needed, if applicable, the required SOFA language or any other language will be added to the PWS at that time.

Section M - Evaluation Factors for Award

"EVALUATION CRITERIA/EVALUATION

APPROACH,

Factor 4 – Cost/Price" p.148-149

Can the Government confirm whether a price realism analysis will be performed? Publicly available data shows that the incumbent vendor has billed at more than double the rate per hour (RPH) compared to their evaluated RPH on the 2018 predecessor contract, which had a similar evaluation structure and approach to this RFP. A realism analysis could help protect the Government from repeat behavior and provide better value to the Army.

No, the Government will not include a price realism analysis as offerors are not permitted to deviate from the prescribed level of effort.

Section C - Descriptions and Specifications

PERFORMANCE WORK STATEMENT, 8.1

TECHNICAL EXHIBIT A - Performance Requirements Summary; 8.2 TECHNICAL

EXHIBIT B - Deliverables Schedule p.47-60

Programs as complex as Army Financial Improvement require continuity of contract support. As such, will the Army consider adding a deliverable that requires vendors to submit quarterly staffing reports highlighting any changes in contractor personnel? Additionally, to measure successful retention, can the Army require that vendors maintain over 95% of key personnel period over period and 85% of non-key personnel?

No, the Government will not consider explicit language to add into the PWS, however, deliverables associated with Task 5.11.1 may be inclusive of staffing metrics and will be determined upon award.

Section J - List of Documents, Exhibits and Other Attachments

Att…

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