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Selecting the Right NAICS Code for OASIS- Seeking Your Feedback

GSA anticipates awarding OASIS contracts to firms that primarily provide knowledge-based services through the knowledge and skills of their professional employees in a manner that delivers a total solution to agency requirements. The primary professional service disciplines covered by OASIS include program management and consulting, professional engineering, logistics, and financial. 

GSA believes that the general scope of services to be provided through OASIS are those professional services generally defined within the North American Industrial Classification System (NAICS) as provided in industry Sector 54, Professional, Scientific, and Technical Services, except those services that may be elsewhere specifically excluded.  

Our preliminary market research suggests that the specific NAICS code, 541611, would best represent the primary services to be provided under task orders.  Therefore, GSA is considering using this NAICS code as the primary code for the OASIS master contract solicitation.

When selecting an appropriate NAICS code for OASIS, our team considered these factors:

            1.  Covers the scope of OASIS           

            2.  Dollar amount contract size standard of $14 million.       

            3.  NAICS covers a business objective not IT objective

            4.  Broad enough NAICS that provides for the complex integrated services outlined in the scope

Our preliminary market research suggests that the specific NAICS code, 541611 would best represent the primary services to be provided under task orders. The Census definition for NAICS 541611 is Administrative Management and General Management Consulting Services.  Moving forward, GSA is now considering using this NAICS code as the primary code for the OASIS master contract solicitation.  

I’d like to get your feedback on this decision. Do you feel that NAICS 541611 is appropriate for OASIS? If not, which code would be more appropriate, and why?

I look forward to reading your responses.

Jim

Groups audience: 

Comments

morganvpi

Jim,

Thanks for opening up the dialogue.  My question is this:  it seems that the general assessment of the type of work that is to be performed under this vehicle as "professional services" lends itself to 541611.   However, other services identified such as engineering and logistics services would more likely align to other NAICS.  For the "professional services" component, it would seem to me that it is very similar to the MOBIS contract SINs 1,2,3,6 7, and 99.  Can you clarify how OASIS will be used differently than MOBIS?  And given an intent to allow "integrated solutions" for our mutual clients, would that not dictate using the NAICS that satisfies the Logistics and Engineering requirements (due to size), knowing that it would be inclusive of smalls that can meet the 541611 standard?  In other words, the lowest common denominator across requirements.  Also, would it not be feasible to consider multiple SINs which align with different NAICS or groups of NAICS similar to a MOBIS schedule?  Thanks again for the dialogue.

OASIS Blogger

Hello and thanks for the question.  First, let me be clear that OASIS is not a GSA Schedule contract.  OASIS will be issued under full and open competition as a FAR Part 15 competitive procurement.  This creates a great number of differences from a contractual standpoint.  From a scope perspective, the scope of MOBIS is but a subset of the scope of OASIS.  Task orders under OASIS will be for complex requirements related to the OASIS core disciplines of: management consulting services, program management services, engineering/scientific services, logistics services, and financial services as well as a variety of ancillary services. With regards to the NAICS code, the NAICS code chosen must represent the primary services to be procured under OASIS. GSA is currently considering all of the comments on this subject under advisement in reaching a final decision on the issue.  Thank you again for your time and feedback on these issues.  Jim

dwalz

Jim,

If the current logic holds, then OASIS (both small and F&O) will be competed with NAICS 541611. You appropriately cite that there are regulatory requirements that dictate how you will ultimately select the code. There are also many posts on here that appropriately point out that this could have a detrimental effect on small businesses just north of the $14M size standard and limit the competitive spirit of small business participation. I was wondering if GSA plans to allot a certain number or percentage of Full & Open awards to companies in the $14.1M - $100M range. There are seriously solid companies that fall into this range and it would be a shame for the perception to be that they were boxed out so that F&O awards could go to the "typical" large business primes that historically win these IDIQs. If there is no plan for this, would the GSA consider the option of Contractor Team Arrangements (CTAs) comprised of solid small to mid tier companies to better compete against the mega-large primes?

Thank you Jim...this is a great tool.

OASIS Blogger

Thanks for your input and suggestions.  To be perfectly honest, we still aren’t sure what NAICS code and associated size standard we will use for the OASIS contracts.  We recognize the value of companies typically considered “mid-sized”, but we simply don’t have the authority to allot a number of awards to them because they are not recognized in the FAR and there is no legal definition of what constitutes a midsize company.  Actually, the rules and regulations establish “small” businesses and “other than small” businesses.  There is no identification of “large” or “midsize”.  We understand Industry’s concern about the size standard and we hope to end up with a resolution that addresses the concern.  You never make everyone happy, but we try to do what we think is fair and reasonable given all factors involved.  Please stay tuned as we move forward and thank you so much for the input.  Jim

MCGroupInc

Jim and team,

Early in the process, GSA stated that the primary professional services included would be: Program Management and Consulting, Professional Engineering Services, Logistics Management Services, and Financial Services. Since then we have seen a variety of industry recommendations focused largely on adding: environmental, security, and energy services. Seems that HR should be in the mix. Although the list of professional services GSA talks about the most under OASIS does not include HR, an example used recently in an article quoting an OASIS team member cited HR as a professional service with IT as an ancillary service on one big possible requirement. I have not seen any clarification on the list of professional services so I have these questions:

1. Have you guys settled on a final list of professional services as a focus?

2. Have you settled on a list of what might be called ancillary services - including, of course IT?

Answering these questions before the draft RFP is issued - or at least providing some further clarification even if the business case is not fully developed - will enable lots of firms to move this procurement up or down their list of priorities as well as determine whether to try and join a team as a sub or lead a team or do both. As you can imagine, teaming is already well underway.

Thanks for any clarification you can provide.

Regards, John Boulware

 

 

 

 

OASIS Blogger

Thanks, John, for the questions. Our initial group of primary professional services was based on our market research and early discussions with several customer groups. We have had industry recommendations for adding others and continue to keep an open mind.  However, the biggest driver of what primary group of services ends up in the final RFP will be the overriding needs of the federal agencies.  That is why it is extremely important for GSA to get feedback from the agencies on the full range of their needs after the posting of the business case. If any professional service area is to be excluded from the scope of OASIS either as a primary or ancillary service, it will be identified in the draft RFP. We understand the significance and import of industry activity ongoing with respect to OASIS, but do not want to make any commitments or decisions we have to later retract because of agency feedback.  GSA appreciates your patience as we work diligently to design an OASIS vehicle that captures the full need of the agencies and accommodates the maximum industry capability and ingenuity.

bmichelson

With focus on engineering services, I would suggest using NAICS 541330 with the exception for Military and Aerospace Equipment and Military Weapons.  This provides a solid match to the tasks planned for OASIS and caps the size standard at $35.5M, which will support a broader range of companies in the competition.  As an alternative, use the generic size standard of 500 employees.  I would agree with others that $14M size standard is too small for the OASIS size, scope, and complexity.

OASIS Blogger

Hello and thank you for the input.  We will take this under consideration as we move forward.  Jim

kminchew

All these discussions are about one thing, do not pick a NAICs code that cuts out any SBA small business size. As long as you can promise that that all small businesses no matter what size can participate, then it is about the right NAICs code to match the work, not about pick mine because it allows under $25.5M or pick mine becuase it is under 500 employees. If you pick 541611 then guess what that limits the size to under $14M and so according to SBA if you bid under that NAICs code and are not underr $14 you are not a small business.

OASIS Blogger

Hello Kathy and thank you for your feedback.  Your point is well taken.  You never make everyone happy, but you can always strive to do the right thing.  Whatever the NAICS code ends up being, the selection of the code will be based on criteria that makes sense for the contracts and is supported by SBA representatives.  Thanks again for your input.  Jim

lqdkj

The Air Force PEO for Services, in collaboration with the Air Force Small Business Programs Office, has decided to broadly use 541712 for "Engineering and Technical Services" contracting throughout the Department. This includes large, center wide systems engineering and integration efforts for aircraft, space, and intelligence systems. Size standards are 500, 1000, or 1500 employees, depending upon program focus. You may want to discuss with them the rationale behind their decision.

OASIS Blogger

Thank you for your feedback, Joe. We would love to reach out to them for discussion. Do you have a specific Point of Contact?  Please send us the information via email if you do and thanks for the suggestion.  Jim

Mojobobby1

Jim and Team:

I'd like to make a suggestion that to many will seem unrealistic but here goes.

1. In my opinon allowing the 500 employee size standard (NAICS 519130) in addition to the 541611 and other relevant NAICS codes, why?

2. This approach gives GSA primes that have nationwide and global abilities without creating a financial hardship to the primes, and

3. By limiting this NAICS category awards, and making these primes maximize small business utilization (e.g. must have all small business categories on their teams) and the prime must report (monthly, quarterly yearly) the small bisiness utilization (meeting a pre-established GSA metric for each category), and if they miss that metric for 2 quarters in a row, they're rolled off the contract and replaced.

4. GSA gets the best of both worlds: Primes that can manage the team and ensure: Highest quality of services delivered,  agile, flexible and highly responsive services - nationwide or globally whenever needed and without the possibility of financial hardships; Maximize small business utilization and simultaneously mentor their small business teammates in managing an IDIQ contract and all that goes with it.

5. End result is that GSA gets: 1. A few primes that ensure OASIS SB success, 2. mentor SB's to be effective PMO managers, 3. Ensure maximum SB partifipation without GSA having to 'manage/administer' the oversight, 4. Significantly reduce the risk of not making all SB metrics on the OASIS SB contract over the life of the contract.

Such a team will result in: Faster responses, Better quality services delivered and lower cost to the government.

Thanks for asking and listening.

Bob Johnson

OASIS Blogger

Thanks for the feedback.  Please also see some of the other blog posts and discussion about the size standard.  I’m not sure how much flexibility we have on this issue, but we will consider everything we can.  Thanks again. Jim

1bighokie

While I think it MIGHT be a fair assessment to conclude that 541611 represents the majority of the work to be performed.  I think several other points are also equally (if not more fair) and worthy of VERY STRONG consideration.  Specifically:

  1. There is no silver bullet formula for allowing the acquisiiton community to make the critical assessment on which NAICS code represents the prevailing majority of work to be included.  This is very much a subjective call and while the vendor community is appreciative of forums like this that allow for transparency and debate....this is a $12B procurement with very high stakes for everyone that provides these services within the government...so having subjectivity in a critical decision with the propensity to eliminate such a wide segment of the small business community is troublesome.
  2. There are definitely multiple NAICS codes that might have a high degree of applicability given the WIDE ranging work that GSA is contemplating peforming under this solicitation.  This has been the prevailing feedback in the thread and points to some of the exlcusion concerns I referenced in point #1.

Why not consider a framework that includes multiple NAICS codes instead of just a single NAICS code?  

I think industry understands that the NAICS code size standards cannot be adjusted.  However, leveraging only a single size standard based on a subjective assessment that has the propensity to eliminate a TON of small businesses that do this work in the $14 - $25M range on a $12B procurement is a strategy that warrants re-consideration. Else, you force every small business $14M to compete against $1B behemoths on a full and open basis.  

Bottom line there are a number of practical and responsible drivers for considering a larger mix of NAICS codes for this acquisition given its scope, mission, and small business community implications. 

 

OASIS Blogger

Hello and thank you for sharing your opinion.  First, let me clarify that no ceiling has been established for OASIS or OASIS SB.  

Regarding the NAICS code selection, while we certainly understand the message, the current regulations governing this in FAR 19.102 are fairly clear and simply do not allow for a multiple size standard approach.  The selection of a NAICS code is not a “strategy” on our part.  It is regulatory requirement.  We ARE exploring options and ideas to try to address this issue, but this issue is not one that we have full authority and discretion to do whatever we would like to do.  Jim

fplath

Have you considered 541712 for its engineering component? Allowing a larger pool of small businesses to participate will provide you access to a greater variety of consulting services and, in the case of businesses that are a little larger, internal management systems that are likely to be more refined. 

OASIS Blogger

Hello and thanks for posting.  This is a very good question and we have had many similar questions come in.  We have considered this NAICS code and bottom line, the OASIS team would love to have the latitude to select whatever NAICS code we wanted to or have the flexibility to re-adjust size standards for given NAICS codes.  But realistically, we have to select the NAICS code that best represents the majority of work to be performed on the contract.  NAICS code 541712 is for research and development, which doesn’t represent the majority of work to be performed on the contract.  This simply isn’t something that we have the authority to do, but thanks for your question and please keep sending in ideas.  Jim 

gharris@s4inc.com

I echo the above comment and feel that the 541513 or 541519 are more applicable NAICS codes.

 

 

 

OASIS Blogger

Thank you for your feedback, Greg. We will take your comment into consideration as we move forward with the RFP development process. Jim

rbrosey

Seems to me 541513 (Computer Facilities Management Services) or even better yet 541519 (Other Computer Related Services) are more applicable.

OASIS Blogger

Thank you very much for your comment, Robert. We appreciate your thoughts on this subject as we move forward with the RFP.  Jim

jsutton

If GSA had a goal of fostering the greatest degree of Small Business Participation, it would select a NAICS code that allows the largest number of Small Businesses to participate. If it does not, it might select a relatively small and restrictive size standard and justify that by referring to antiquated SBA standards whose reform has been ongoing but unresolved. 

GSA has the opportunity to allow greater participation by qualified and experienced Small business by choosing a NAICS code for the OASIS contract that allows an employee size standard of 750 or 1500 employees.  The Air Force has done that for eight/nine years in the NETCENTS contract through use of the NAICS 517110 size standard.  The Air Force did this for RISK REDUCTION reasons in 2003 but the precedent is a one good. 
 
GSA should consider NAICS codes that use a different SB measurement other than <$14M (or <$25 million) annual receipts as a company that small may not be fully qualified to manage a major GSA contract or be able to provide the breadth of services discussed. A NAICS that measures SB qualification by number of employees might be better suited for OASIS. These companies would have the resources to prime OASIS yet still being considered small.
 
OASIS Blogger

Hi Jim, 

The Air Force NETCENTSII contract is for telecommunication and IT services.  In general, IT NAICS codes have larger size standards (both dollars of receipts and numbers of employees) assigned by the Small Business Administration (SBA), consistent with the nature of that Industry relative to other industries.

OASIS will have a professional service, rather than IT, objective as the primary purpose of its scope.  

Our goal is to create maximum opportunities for Small Businesses whose primary business services fall within the Industry represented by the scope of OASIS.  We have tentatively identified the NAICS code of 541611 as most representative of the majority of services to be procured under OASIS.

Thanks for your interest and participation in this important dialogue.

Jim

 

caldgargan

Where can we find a listing of the requirements for the OASIS contract so we can compare this NAICS code with the requirements?

OASIS Blogger

Hi Richard, and thank you for your question.

We are still in the acquisition planning phase of OASIS. A draft RFP is expected to be released at the end of this summer which will provide details on the scope of OASIS.  For now, we are working under the assumption that the scope of OASIS will include the following professional services: program management consulting, logistics, professional engineering services, financial services.  Based on that, we are trying to find the NAICS code that best represents the primary services to be provided under task orders. 

Jim

thomson

Yes, NAICS Code 541611 does best describe the core service areas intended for the OASIS contract vehicle.

OASIS Blogger

Carrington, thank you for your feedback.

Smartronix_GWAC

Jim, a recent and very relevant $3B BPA within the Marine Corps called CEOss (Commercial Enterprise Omnibus Support Services) established several domain areas of support to include Specialty Engineering (SE), Business & Analytical (BA), Engineering & Scientific (ES), and Acquisition, Logistics & Admin (ALA) in order to cover all A&AS requirements.  They found it necessary to choose two NAICS across these 4 domains.  SE, ES, and ALA used 541330; while BA used the 541611 that you have proposed for OASIS.  It may be an advantage to select more than one NAICS depending on how the basic contract is constructed.  Good luck!

OASIS Blogger

Hi David, Thank you very much for your comment.  We are considering that NAICS code 541611 would best represent the primary services to be provided under task orders.  We are also conducting market research on the possibility of having more than one NAICS code at the master contract level.

We appreciate you taking the time to share your thoughts on this subject. 

Jim

bgillette

Does this mean that only firms with a 3 year revenue average of 14m will be able to prime?

OASIS Blogger

Hi Bob,  Thank you for your question. No, the $14M threshold does not dictate who can be a prime under OASIS. The threshold is the size standard of a business under the NAICS.

Jim

robiewood

I concur that the use of 541611 is the best category to meet the requirements for OASIS as I understand them.  To be more specific would probably require a long list of codes to get at every possible nuance of service type that may be solicited under this vehicle.  I think 541611 provides the needed flexibility.

OASIS Blogger

Thank you for your input, Robie. We appreciate you taking the time to share your thoughts on this subject.

Jim

chashina

Jim,  Please explain the use/intent of a $14M size standard. Thank you.

OASIS Blogger

Thank you for your question, Annette. There are about a dozen NAICS codes within Sector 54 that can be used to describe the various services that will be integrated under OASIS to provide total solutions to agencies needs. The small business size standard that SBA has assigned to the majority of these NAICS codes is $14 million. We are considering the NAICS code that we believe is the best fit for OASIS in following the general rule for assigning NAICS codes.  We believe the NAICS code proposed in the blog best represents the majority of the work under OASIS.  The associated size standard for that NAICS code is $14 million, which as stated earlier is pre-determined by the SBA.  Please note also that the SBA recently raised these size standards from $7 million to $14 million.

Jim

rockchalk

Would this NAICS limit the ability to provide Engineering, Logistics or Financial Services support as part of a requirement?  Each of those services is covered by a separate NAICS  - yet the All other code, excludes all of these.  Somehow, you are going to have to include the other NAICS in order for the task orders to pass the scope test, aren't you?

OASIS Blogger

Hi Mary, and thank you very much for your questions.  We are considering that NAICS code 541611 would best represent the primary services to be provided under task orders.   Work that falls under other NAICS would be in support of the primary NAICS and could be included in task orders.  The primary scope test for proposed OASIS task orders will be whether the proposed order has a professional service objective. Please let us know if you have further questions or comments.

baroberson

I think 541611 is the best fit.

OASIS Blogger

Thank you for your feedback, Beth.

Jim

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