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 has created six ‘pools’ for OASIS and OASIS SB which will be used to determine business size at the master contract and task order levels. These pools, as identified in Attachment 3 of the draft RFPs, are as follows:
- NAICS various, see Section J.3, Size Standard $14.0M
- NAICS various, see Section J.3, Size Standard $19.0M
- NAICS 541330, Exceptions A-C, Size Standard $35.5M
- NAICS 541711-541712, Size Standard 500 employees
- NAICS 541712, Exceptions B-C, Size Standard 1,000 employees
- NAICS 541712, Exception A, Size Standard 1,500 employees
Contractors bidding on OASIS SB can only propose the pools in which they meet the size standard. For example, if your company has $21.0M in revenue and 520 employees, you can only bid OASIS SB for pools 3, 5, and 6. GSA intends to make 40 awards in each pool on both contracts, but contractors can bid on any or all of the pools the qualify for. At the task order level, the NAICS code will be used to determine which pool a task order is competed in.
Please note that the NAICS codes are provided for size determination ONLY and do not directly correspond to the core discipline or labor categories. Additionally, contractors do not have to provide past performance per pool, just five TOTAL past performance citations.
Stay tuned for the next post in our special OASIS series, which will cover past performance requirements.
Author: Jennifer Aubel
For more information contact Hope A. Lane, Partner at Aronson LLC’s Government Contract Consulting Practice.
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