By Steve Delahunty
The updates to the final GSA OASIS+ procurement may provide the GovCon industry with insights as to what we should expect for the forthcoming GSA Polaris procurement amendment(s). As a reminder, GSA issued an Amendment via SAM.gov on June 29th noting, “In response to a Court of Federal Claims decision, GSA plans to issue an amendment to the Polaris GWAC solicitations.” This is reflected in the four (4) procurements for Polaris:
The Chatter
Per the GSA Interact community feed on the subject of the GSA OASIS+ procurement, in May it did appear that GSA was assessing and accommodating the impacts of the Polaris case law outcome. “GSA’s Office of Professional Services and Human Capital is still finalizing the acquisition strategy for the new OASIS+ contract program.”
And various industry sources also confirmed that the final OASIS+ procurements were delayed due to the US Court of Federal Claims (USCFC) decision on the Polaris protests.
The April 21st USCFC GSA Polaris protests ruling was in favor of several Mentor Protégé (MP) Joint Ventures (JVs) (MP/JVs) whose protests on the Polaris bid related to how the protégé project submission requirements were handled. That USCFC decision halted further proposal evaluation and contract awards under the current versions of the Polaris solicitations.
Potential Paths
Included here are the Polaris protest outcome highlights and our thoughts on a likely Polaris amendment based on how the GSA OASIS+ updates appear to have accommodated the protests into the final OASIS+ procurements:
MP/JV Projects from the Protégé. The protest decision means GSA will need to establish how they adjust the bid requirement that had previously mandated that all JV bids have at least one corporate experience project or emerging technology project from the JV lead. The court ruling basically says that GSA cannot require one such project from the MP/JV Protégé because that is not how SBA allows past performance or projects to be used in a MP/JV bid. Note that this does not necessarily impact how GSA handled typical bidding JVs but just MP/JVs.
GSA OASIS+ has handled this in an interesting fashion, still requiring at last one (1) Qualifying Project (QP) from any MP/JV bidding which can be from the Protégé firm or from the JV itself if that JV entity has a project to submit. But GSA is providing lower barriers for minimum annual dollar value for the QPs or Federal Experience Projects (FEPs) from MP/JV Proteges and such projects can come from the JV itself. Note however that the QP Scale point scoring is still the same level for any firm regardless of MP/JV or not.
We believe that even a “non-relevant” QP can be used for this MP/JV project requirement but that may be open for interpretation and outcomes of ongoing OASIS+ Q&A.
Perhaps for the GSA Polaris amendment we may still expect that a MP/JV Protégé will need to submit at least either one (1) Relevant Experience Project or one (1) Emerging Technology project. It is possible that the Individual Project Value requirement may be lowered from the previous requirement for obligated dollars equal to or greater than $250,000 (example for Small Business) to something lesser.
Costs and Pricing. On the initial GSA Polaris procurement there was no pricing submission required. Due to the protests, expect that bidders likely will be required to submit Polaris IDIQ level bid rates and supportive price narrative, and pricing data as an outcome of the court decision. On the GSA OASIS+ procurement, pricing was not listed in the drafts. However, in the final procurement, which was adjusted post Polaris protests, the proposal submission does require a government pricing sheet for twenty (20) Subject Matter Expert (SME) level labor categories providing Direct Labor (DL) rates and bidder indirect burdens. Submission also requires a price narrative and various supportive price data, including proof of the bidding firm’s indirect rates (govt documentation as a Forward Pricing Rate Agreement or three (3) years of historical indirect data showing proof of that data from the bidder’s accounting system).
Post award, GSA OASIS+ will be using the full set of Department of Labor (DOL) Bureau of Labor Statistics (BLS) Standard Occupational Classification (SOC) labor categories at the task order level. GSA Polaris had been more Information Technology (IT) focused, compared with GSA OASIS+ in which the IT work is ancillary. This means we may expect either a subset or full labor category mix similar to what was used for GSA STARS III.
About the Author
Steve Delahunty is the Chief Executive at Arcetyp LLC providing oversight of consulting services and engagement management across the firm’s client base. Arcetyp provides business growth and business operations consulting services to firms in the US government contracting industry. Mr. Delahunty is a senior leader with 17 years of GovCon executive experience in technology and management consulting and over 30 years in the IT field. He has held client facing consulting positions with top tier firms including Booz Allen Hamilton, SAIC, Tetra Tech, and Stanley Associates. Mr. Delahunty is a regular technology conference speaker, panel member/moderator, and author of over 40 print published articles and industry reports.
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