UPDATE Four 7/22/13: Is GSA OASIS Right for Your Company? Draft RFP Revisions Out, Final RFP Coming Soon!!
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:
- Are you primarily an IT service provider? If yes, then GSA’s OASIS is not for you.
- Are you able to develop viable pricing models for standardized labor categories under enormous rate pressure? Will those rates stand up to additional competition at the task order level?
- Do you have the infrastructure in place to meet extensive reporting requirements? Are you able to capture and report transactional level sales data for commercial and non-commercial items?
- Can you meet the statutory requirements of the Service Contract Act (SCA), if necessary?
- Joint Ventures (JV): Do you have adequate past performance as a JV to meet the solicitation requirements? A JV cannot rely on the past performance of its member companies to support its proposal.
Large Businesses (over $35.5M)
- Past Performance: Can you demonstrate past performance with projects integrating at least four of the five functional areas (program management, management consulting, professional engineering, financial services, and logistics)? You may only include past performance from other companies if they were subcontractors on such a project (i.e. cannot propose a team).
- Small Business Utilization: Are you capable of meeting a 50.0% small business subcontracting goal? Non-compliant contractors will be at risk of involuntary off-ramping. Also, FAR Part 19 “Rule of Two” applies to OASIS task orders.
- Accounting Systems: Do you have an approved accounting system?
- CAS Coverage: OASIS is fully covered under the Cost Accounting Standards (CAS).
- Business Systems: Approved purchasing and earned-value management systems are NOT required, but earn credit in evaluation
Small Businesses (under $35.5M)
- Past Performance: Can you demonstrate past performance with projects integrating at least three of the five functional areas (program management, management consulting, professional engineering, financial services, and logistics)? You may only include past performance from other companies if they were subcontractors on such a project (i.e. cannot propose a team).
- Accounting Systems: Do you have an approved accounting system?
- Merger and Acquisition Considerations: When OASIS SB contractors are purchased by large businesses, they can no longer compete for new OASIS task orders. Companies will not be able to buy their way onto OASIS so holding this contract will not improve your valuation for acquisition.
Unfortunately, there are still many unknowns regarding OASIS, but we expect the draft RFP to clarify many of these issues. Although GSA has not given a projected date for the draft, we currently expect it to come out before summer, which will help contractors decide if OASIS is right for them. Stay tuned to Aronson FedPoint for more OASIS news as it becomes available including a webinar covering the draft RFP upon its release.
Author: Jennifer Aubel
For more information contact Hope A. Lane, Partner at Aronson LLC’s Government Contract Consulting Practice.
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