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Exploring OASIS: The Revised RFPs (Posted on June 27)

A few days ago we posted the revised RFPs which we promised at our Industry Day in mid-May.  I hope by now that you’ve had time to review the documents and look forward to your comments and feedback.  In this blog entry I’d like to discuss some of the major changes we made.

One of the themes which we heard over and over again in our One-on-One sessions and in the comments received in response to the draft RFPs was that there seemed to be no connection between the pools and the disciplines as defined in Section C.  As things stood in the original, companies with no R&D experience at all, for example, could win in Pools 4 thru 6, which will involve predominantly R&D work.  Our initial response, which still stands to a large degree, was that the scope of OASIS and OASIS SB involves integration of complex professional services across multiple disciplines.  Companies which could successfully integrate those disciplines in one area could likely do it in any area.  Based on the feedback we received from industry and our customers, however, we saw that there was great value in ensuring that companies which win in a particular pool demonstrate at least some experience specific to that pool.  For this reason, we’ve decided to require that one of your Relevant Experiences come from work done in each pool in which you are bidding.  There are 6 pools, but 3 of them represent exceptions to NAICS codes listed in other pools.  If you qualify for Pools 1, 2, and 4, you qualify for them all. What this means is that companies in the R&D pools, for example, will have some demonstrated experience in doing R&D work.  We think this change will result in greater variety between the pools and allow greater opportunity for more focused, mid-sized companies to compete on a more even playing field, which was also a theme we heard repeatedly. 

The next major areas to be addressed are related to how we scored commercial experience as opposed to federal experience. First, we did not (and still do not) believe that OASIS should be a company’s first foray into government contracting.  There are a great deal of unique features to government contracting and there is great value to our customers in knowing that all OASIS and OASIS SB primes know how to manage the federal procurement process.  Second, we had concerns about the relative trustworthiness of past performance reports from warranted Contracting Officers versus those received from commercial business partners.  It is not, and never was, our intent to prevent companies with outstanding and innovative commercial solutions from bidding successfully.  Thus, we realized that our initial scoring system penalized commercial work in multiple areas:  we required 3 out of 5 experiences to be federal, we gave points to various systems, etc. which are unique to government contracting, and then we also gave fewer points for equivalently-rated commercial past performance.  We’ve listened and made adjustments, however.  Our decision to require experiences tied to the pools being bid removed the need to require experiences to be government.  By definition, only federal experience will have a NAICS code formally associated with it; therefore, we do not need additional restrictions on commercial experience.  We also realized that enough scoring factors lean favorably toward government work that we do not need to explicitly downgrade the scores of commercial experiences.   There are a number of factors in play for any given Relevant Experience.  As I’ve stated before, we don’t expect any perfect scores, even for individual experiences.  Some commercial work will score out higher than some federal and vice versa and that is fine with us.

The last major change I’d like to discuss today relates to Key Personnel.  We initially had scoring elements related to the education, experience, and certifications held by proposed Key Personnel.  We heard over and over again, however, that this was encouraging companies to bypass otherwise excellent candidates for these positions so as not to “give away” points.  It was certainly not our intent to keep good people out of the program.  Upon further consideration and discussion, we decided to simply eliminate these factors from the scoring.  All OASIS and OASIS SB contractors will have to manage their contracts successfully and they will need solid people to do that.  If they fail to do so, we can hold them accountable as needed.  Dormancy provides a great tool in this area.  We trust that companies will bring the right people to the task and we will hold them accountable if they do not.  That will more than suffice.

Of course, there are a number of other changes and I may address those in the future, based on your feedback and questions.  I hope that it is abundantly clear, however, that we did listen to the feedback received, that we did consider it thoughtfully; and that it did impact the procurement.  We have learned a great deal and gotten immense value out of the ongoing dialog that has taken place in this community and we hope to continue in that vein for the life of the program.


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<p>Hi Jim,</p><p>I have a follow-on question regarding Attachment 8. You state here and also in the draft Q&amp;A that bidders must propose pricing for all labor categories. If a bidding company does not have any actuaries on staff, for example,&nbsp;what should the basis for their pricing for the actuary categories be? I saw that you mentioned that salary surveys might be accepted in the draft Q&amp;A, but I didn&#39;t see anything else about this. Thanks!</p><p>Jennifer</p>
<p>Thanks for the revised Draft RFP and communications. GSA is doing a good job of communicating on this solicitation. Many of the revisions to the Draft RFP have helped improve the solicitation.</p><p>We are very concerned with one requirement, where GSA is using NAICS codes of the offeror&rsquo;s Relevant Experience contracts to as one method to determine contractors eligibility to bid on OASIS SB and OASIS. Section L.5.3.1. Minimum Requirements for Relevant Experience Projects, on pages 89 and 90 requires that at least one Relevant Experience have a reported NAICS code that directly corresponds to the pool the contractor is responding to.</p><p>According to the US Census; &ldquo;NAICS is based on a production-oriented concept, meaning that it groups establishments into &lsquo;industries&rsquo; according to similarity in the processes used to produce goods or services.&rdquo; The intent of the NAICS code was never to classify the &ldquo;type of work performed within a contract&rdquo;, but to classify businesses into industries and set small business size standards.</p><p>According to the Federal Procurement Data System Product and Service Codes Manual, August 2011 Edition published by GSA, &ldquo;product/service codes are used to record the products and services being purchased by the Federal Government. In many cases, a given contract/task order/purchase order will include more than one product and/or service. In such cases, the Product or Service Code data element code should be selected based on the predominant product or service that is being purchased.&rdquo;</p><p>Thus, we believe that for OASIS and OASIS SB, GSA is utilizing the wrong federal classification code (NAICS) to determine the types of services on a offeror&rsquo;s Relevant Experience contract. We believe that GSA should follow their own guidance published in the FPDS PSC Manual and utilize the Product Service Codes (PSC) on contracts within FPDS to determine the types of services on a offeror&rsquo;s Relevant Experience contract, not the NAICS code that is used to loosely group companies into industries and to set small business size standards. This slight change will be beneficial to GSA as it would:</p><ul><li>provide consistency in the use of NAICS and PSC codes per their definitions and practical use by the federal government</li><li>utilize FPDS and the PSC Codes to confirm the services procured on a contract (as defined by GSA in the FPDS Manual) are appropriate for OASIS via the PSC code (Codes including &ldquo;CXXX&rdquo;, &ldquo;RXXX&rdquo;, and possibly a few others)</li><li>utilize NAICS codes appropriately to classify businesses by their actual size still utilizing the Pool groupings and definitions within the solicitation</li><li>provide GSA offerors that have the proven, past experience (via validation of PSC codes) to perform the scope of services defined within OASIS.</li></ul><p>This change also removes some of the issues and flaws with the use of NAICS codes to determine types of services procured, including:</p><ul><li>NAICS codes were never intended to be utilized to determine the services or products procured</li><li>Contracting Officers (CO) utilize NAICS codes for size standards. Thus, many times a CO will utilize a NAICS code such as 541519 to procure Project Management services and to open the bid to organizations under $25.5M, even though there are not IT services being procured. As opposed to using a NAICS code of 541611 or 541990 ($14M size standard) &nbsp;&nbsp;</li><li>Does not penalize contractors that competed above their size standard on a solicitation (For example, many procurements for OASIS type services are released under NAICS code 54151X to reach contractors within the $25.5M size standard. If the services that are procured are non-IT, OASIS type services (verifiable via the PSC), contractors that fall within the $14M size standard that win this work are the types of proven contractors GSA has stated they are looking for (proven contractors that can compete with larger organizations for OASIS type services).</li></ul><p>In speaking with other contractors, I know others have the same view point. Anyone else want to chime in here???</p><p>&nbsp;</p><p>Thanks!&nbsp; Phil</p>
OASIS Blogger
<p>Hi Phil and thanks for the feedback.&nbsp; We plan on removing the NAICS code examination for Pool application from the Relevant Experience projects.&nbsp; Please see the update released on July 3rd.&nbsp; Btw, a situation where a contracting officer intentionally uses an incorrect NAICS code to increase the size standard is both inappropriate and unethical.&nbsp; If intentional, that would likely be grounds for having his/her warrant taken away.&nbsp; Jim</p>
Bill Hack
<p>When do you anticipate posting Section J-7, Subcontracting Plan Template?&nbsp; It was not provided in the earlier draft and I do not see it.&nbsp; Am I missing something?</p>
OASIS Blogger
<p>As we mentioned in the blog, we didn&rsquo;t release the attachments yet as we are still working on them.&nbsp; For this particular attachment, however, please see the Attachment 7 from the OASIS draft solicitation.&nbsp; They should be very similar.&nbsp; Jim</p>
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