GSA posted the revised draft solicitations for OASIS and OASIS SB in late June. The revised draft makes significant changes to the requirements for relevant experience, including the point allocations. The changes are summarized below in blue as part of this update to our previous post on this topic.
Potential bidders must understand when selecting relevant experience that TEAMING WILL NOT BE CONSIDERED at the MASTER contract level; all relevant experience examples must be
UPDATE (7/23/13): The revised draft solicitations for OASIS and OASIS SB made one major change in regard to bidding for particular pools. GSA is now requiring bidders to provide projects demonstrating experience in all pools applied for. Please note that, according to Jim Ghiloni via the OASIS Industry Community on GSA Interact, although the revised draft states that the projects mapping to NAICS Codes (as reported in FPDS) would come from the five relevant experience projects, this will change in the final RFP. Points will still be awarded to companies using projects with OASIS NAICS Codes reported in FPDS for their relevant experience.
GSA anticipates that projects supporting particular NAICS Codes (and therefore pools) will be submitted in addition to relevant experience, similar to how the Mission Spaces requirement is being treated under the revised solicitation. The proposed change requires OASIS SB bidders to submit two prime contracts per pool they are bidding on and OASIS bidders to submit three. All projects must have at least a 3.50 rating for past performance. Exactly what project documentation must be submitted is unclear, but under the Mission Spaces requirement, bidders only have to submit the contract award documentation. Again, this requirement is still very much in flux, but you should be aware that the requirement in the revised draft solicitation WILL change.
UPDATE (5/3/13): One important point I failed to mention is that on OASIS SB, GSA intends to award at least three spots in every pool to the following socioeconomic groups-8(a), SDVOSB, HUBZone, WOSB, and EDWOSB. This does not mean that only 25 of the 40 spots in a pool are available for other small businesses, though. The top 40 evaluation will proceed “blind” to socioeconomic status. If there are not at least three representatives from a particular socioeconomic group in the top 40 for a given pool, additional awards will be made to the next highest rated qualified bidder(s) in that group until there are three.
Welcome to the first post in a special series about the GSA OASIS draft RFP. First a disclaimer – all posts are based on information obtained from the OASIS draft RFP and the most current Q&A available on the OASIS Industry Community on GSA Interact. Changes are certain to occur between the draft solicitation and the final; Aronson will identify major known changes as soon as we are aware of them. Please subscribe to our RSS feed to follow this series and to make sure that you receive breaking information as it happens!
Today’s post will discuss the use of NAICS code ‘pools’ to determine a contractor’s size status and eligibility to bid on OASIS SB. Initially, GSA had intended to base the size standard for OASIS SB on a single NAICS code (541330 exception, $35.5M) based on market research concerning the preponderance of work likely to be awarded under the vehicle; however, a recent rule proposed by the Small Business Administration (SBA) caused them to change this approach. Due to the provisions of Section 1331 of the Small Business Jobs Act of 2010 and concerns about the improper allocation of small business credit under multiple-award contracts, the SBA plans to make significant changes to the FAR. Under the proposed rule, “the contracting officer may divide a multiple award contract for divergent goods and services into discrete categories, each of which is assigned a NAICS code with a corresponding size standard.”
In order to accommodate the probable rule change, GSA
UPDATE 7/22/13: GSA’s OASIS Program Team released its revised draft RFP late last month. There have been several minor changes that affect the systems, certifications, and clearances evaluations. Firstly, DCAA has agreed to audit the accounting systems of all apparent winners who do not have an approved accounting system. Although third-party accounting system reviews will no longer be accepted to establish adequacy, contractors without an audited accounting system should consider a third-party review to ensure that their system is approvable by DCAA before bidding. Bidders with an audited accounting system already in place will now earn points.
Additionally, OASIS will now be scored on a 10,000 point scale. Contractor systems, certifications, and clearances account for up to 20% of available evaluation points. The list of the relevant systems, certifications, and clearances and their corresponding point totals has been updated in the post below. Finally, GSA now includes the ISO 17025 certification.
Thank you for continuing to follow our special GSA OASIS blog series. Before discussing the requirements on OASIS and OASIS SB for contractor systems, compliance, and certifications, a disclaimer – all posts are based on information from the OASIS draft RFP and the most current information available on the OASIS Industry Community on GSA Interact. Changes are certain to occur between the draft solicitation and the final RFP; Aronson will identify major changes as soon as we are aware of them.
Before making a bid decision, companies must understand that simply meeting the minimum solicitation requirements will not be enough to win an OASIS contract. GSA wants to award to ‘best in class’ contractors, so points are only awarded for exceeding the minimum requirements. Although only 20% of the total points are currently allotted to to systems and certifications, these could be critical differentiators if the competition is as intense as we expect. GSA stated in the most recent RFP Q&A that it did “not anticipate that many, if any, Contractors will have all systems and certifications that are encouraged. The evaluation process is about distinguishing between Offerors.”
There has been a lot of confusion regarding which systems and certifications are actually required. The purpose of this blog is to summarize what is actually a requirement versus what is merely a recommendation.
UPDATE 4 (7/22/13): In response to the questions and suggestions received from industry and government in response to its initial draft RFPs, GSA released revised OASIS and OASIS SB draft RFPs in late June. There have been some major changes to the solicitation requirements that may impact your selection of projects for relevant experience and NAICS Code pools, among other things. Updates on specific requirements will be made in the relevant posts from Aronson’s OASIS Blog Series. Information contained in previous OASIS posts may no longer be valid; please consult the most recent updates dated July 2013 for current details!
UPDATE 3: The GSA OASIS Program Office released important updates on Tuesday regarding both the OASIS / OASIS SB draft and FINAL RFPs. Most importantly, the new estimated release date for the final RFP will be in July (after the holiday). Before the final RFP comes out, the Program Office will release updated draft RFPs incorporating the changes that resulted from the initial comment period, including changes to the scoring methodology. According to Jim Ghiloni, “we will be moving to a 10,000 point total…it makes the relative percentages of any given scoring item easy to see…The philosophy of Past Performance and Relative Experience being roughly equivalent and significantly higher than Systems, Certifications, and Resources will not change, but some of the specifics will.” Accordingly, there will be a “last call” for comments on the draft RFP. You can submit comments on the OASIS Industry Community on GSA Interact or send them by email to firstname.lastname@example.org.
UPDATE 2: The GSA OASIS Program Office just made this important announcement about the accounting system requirement: “We are removing the requirement to have a DCAA audited accounting system as a Pass/Fail element. However, Offerors must still have an accounting system that meets FAR requirements. While a DCAA audited accounting system is preferable, we will allow companies with accounting systems that have not been audited by DCAA to compete for an OASIS award. In order to meet the minimum requirements, a Non-DCAA audited accounting system must be operational and have been audited by either a cognizant non-DCAA government auditor or an independent, third party accounting firm that has certified the accounting system for compliance with the same standards set forth in SF1408, Preaward Survey of Prospective Contractor Accounting System AND FAR Part 31. Recognition of already having a DCAA audited accounting system is now present in the scoring system as a significant factor.
If you want to bid on OASIS and do not have a DCAA audited accounting system, Aronson’s financial compliance team can perform 1408 Accounting System Reviews that meet the updated requirement. For more information, please contact Nicole Mitchell at (301) 222-8231 or email@example.com.
Judging by the attendance at recent industry events focusing on GSA OASIS, this contract vehicle for complex integrated professional services appears on many companies’ “must win” list. Although GSA has yet to release the highly anticipated draft RFP, information about this multi-billion dollar contract continues to trickle out of the Program Office. Prospective bidders got their most in-depth look yet at OASIS when GSA released the redacted version of its business case to the Office of Federal Procurement Policy (OFPP) via its GSA Interact OASIS Industry Community. When considering the business case, along with all the earlier intelligence, it is apparent that priming OASIS will not be a possibility for many companies. GSA reports that its overall evaluation process will be based on a combination of “Past Performance,” “Relevant Experience,” and “Systems, Certifications, and Resources,” therefore some contractors will likely be hard-pressed to demonstrate the breadth and depth of past performance needed or meet the system requirements to be eligible to respond.
So, how do you know if priming OASIS is right for your company? Consider the following:
As a follow-up to Aronson’s webinar on “Making the Grade: the NEW Contractor Assistance Visit (CAV),” Aronson LLC government contracting specialists Wade Prince and Vanessa Payne have prepared answers to several attendee questions:
What is the difference between Other Direct Costs (ODCs) and Open Market items? Is travel considered an ODC or an Open Market item? Do I need to include ODCs and Open Market items in my GSA Schedule Contract Industrial Funding Fee (IFF) quarterly reporting and remittance?
Open Market items are a type of Other Direct Cost (ODC) with the distinctions indicated below. ODCs are charges in direct support of a service/order requirements. To the extent possible, all anticipated ODCs associated with the performance of, and within the scope of, the GSA Schedule contract should be identified on the proposal and task order and have an established contract price. Contractors are reimbursed only for incurred costs at or below published “not to exceed” levels.
ODCs typically come in three categories: