Blog Post

AF- ECMM Pricing Synopsis

  • By Michael Gallo
  • 19 Feb, 2019

Summary

This $100M follow-on contract seems to have escaped credible competition for the last 10+ years. We’re curious to see if the current large business incumbent can work their magic through a SDVOSB partner and maintain their iron grip on this contract.

Background

The draft solicitation, FA8003-19-R-A002, is designated as a Service-Disabled Veteran Owned Small Business (SDVOSB) set-aside. The Air Force contemplates award of a single 60-month contract consisting of a base period and (4) 12-month option periods.

The ECMM program is designed to provide medical logistical support personnel for routine staffing at various locations for assemblage packaging of War Reserve Materiel (WRM), inspections, and audits; and provide medical logistical support personnel for temporary surge in workload for contingency, humanitarian, and base exercises. The same services are provided to top secret locations under the JANUS project, which is a classified, strategic, national medical contingency program. The work is segmented into four parts: (I) Air Force Medical War Reserve Material Industrial Operations, (II) Consolidated WRM Storage and Deployment Centers, (III) Maintenance Support Services for Other CONUS/OCONUS-P SME Staffed Locations, and (IV) Maintenance Support Services.

This legacy program has a curious 12-year contract history. As far as we can determine, only a single contractor has bid on this effort to date. First, a $7.8M delivery order was awarded to CACI-ISS (FA4452-09-F-0001) under a Department of Veteran Affairs IDIQ contract (VA798-P-0002) in October 2008. It grew modestly to $8.2M at completion in December 2012. Meanwhile, a separate and larger Air Force Medical Support Activity War Reserve Materials (WRM) In-Garrison Maintenance IDIQ contract (FA7014-08-D-0017) was awarded to the same prime in March 2008. This 60-month IDIQ contract grew from $85M to $93.9M and expired in April 2013. Next, the U.S. Army Health Care Acquisition Activity (HCAA) awarded a 5-month $6.7M sole source bridge contract (W81K04-13-D-0031) in May 2013. The Army let the contract expire for the follow-on GSA Professional Support Services (PSS) task order (W81K04-13-F-0013) awarded in October 2013. The 60-month task order (still managed at the time by the Army) grew slightly from $74.8M to $75.6M at completion. An Air Force 2018 Justification & Approval, indicates the Air Force resumed responsibility in 2018 and issued a 24-month $33.4M sole source contract to the same incumbent. This most recent sole source contract (FA8003-18-C-0003) reflects the current incumbent contract.

Pricing Details

The Air Force will award (1) contract with an expected base period start date of 2/1/2020. The award will be made based on ‘best value’. Consistent with the legacy contracts, this solicitation is considered a commercial item acquisition. Furthermore, since RFP states the Contracting Officer has determined an expectation of adequate price competition, pricing requirements and documentation are very streamlined. And, by utilizing a fixed price contract, there is no requirement for cost data, cost analysis, or subsequent cost realism analysis. The Government will perform only price analysis and ensure offeror pricing is not unbalanced.

There is currently no requirement to provide a cost and pricing narrative nor a basis of estimate (BOE). The draft RFP requests offerors to complete the Excel pricing attachment. The draft pricing template contains 27 CLIN/Sub-CLINs of which (7) are pre-populated plug figures for travel, training, and Transition In/Out period. Separate tabs by CLIN/Sub-CLIN are used to input labor hours. Labor rates are automatically fed into these CLIN tabs from a centralized labor rate tab. The template collates all CLINs into a summary tab which contains a Base and (4) Option Years.

The labor rate tab identifies labor rates for 33 different locations. The template comes pre-populated with 13 labor categories that are common for each location. The pricing template requests fully burdened rates inclusive of profit/fee. As stated above, the template is very straightforward and does not request any cost breakdown of labor rates nor request any details on offeror indirect rates or their profit objective.

Some Pricing Questions

Despite the very streamlined pricing requirements and (non-existent) pricing narrative requirement, we think offerors should seek some pricing clarifications on the following:

  • SCLS Covered Positions. Although the contract contains SCLS clauses and the Government confirmed (in their answers to industry) that the contract will contain SCLS covered positions, the current draft RFP does not contain any Department of Labor Wage Determinations. Offerors should ensure the final RFP contains all relevant Wage Determinations.
  • Overtime Pay. Section 5.5.2 states, "The Offeror shall submit fully burdened base and overtime hourly rates (inclusive of direct costs, indirect costs, and profit) for each of the labor categories located in the Pricing Workbook (Attachment X)." However, the current draft pricing template does not appear to accommodate separate base and overhead rates. Offerors should request the Government clarify this requirement.
  • Template Modifications. While the RFP (specifically Section 5.5.3) would appear to permit offerors to use alternative labor categories, we would be very careful about making any changes to the pricing template labor categories. The current template is partially locked which would prohibit offerors from copying the formulas correctly. In fact, all the pre-populated formula cells have been locked down and cannot be selected to edited. Making such changes is likely to break the pricing template. We think offerors should request that the Air Force completely unlock the pricing template.

Conclusion

While the pricing requirements for the draft RFP are very tailored, a solid understand of the underlying contract requirements is still needed to sufficiently estimate labor hours. The Air Force has provided a significant amount of logistics data, by location. Offerors should ensure they have a solid underlying basis for their labor estimates in case the Air Force decides to ask for clarifications or conduct discussions.

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After months of wondering what happened to your proposal submission, the Government has responded with pages of pricing questions. Now what? Here’s three tips to help you answer pricing questions.

Common Issues

 Generally, cost and pricing questions fall into four broad issue areas:

  • Omission  The Government believes something is missing from your price proposal. It could be something as simple as a sub-total calculation error or something more serious such as unpriced tasks that are identified in your technical volume, but not included in your price.
  • Necessity  The Government believes something priced into the proposal is not relevant or ‘in-scope’. Sometimes a lack of a clear explanation of how costs were derived and or calculated can also lead the Government to question certain costs. Lump sum costs, without underlying details and explanation, are a great example of this.
  • Consistency  The Government believes something in your pricing doesn’t align with your technical volume. This can occur when last minute pricing drills shave costs (such as staff hours), but the change is not reflected in the technical volume (or vice versa).
  • Reasonableness/Realism  If the Government says a particular cost appears ‘unreasonable’, they’re saying they think it’s too high. Conversely, if the Government says a particular cost appears 'unrealistic', they’re concerned it's too low.

Three Helpful Tips

How should companies respond to these questions?

1.     Don't fight the Fed.

Even if you disagree with the evaluator's question, keep in mind there’s something unclear in your proposal that created ambiguity and doubt in the evaluator’s mind. Don’t take it personally. Avoid argumentative language in your responses that just serves to aggravate the evaluators and doesn’t help you to address the issues raised. The fact that the Government may think a proposed cost might be too high (or too low) doesn’t necessarily mean you should revise your price. Often the Government uses terms such as ‘Justify’, ‘Substantiate’, ‘Clarify’, ‘Explain’, etc. to describe their need for additional information.

2.    Fortify answers with facts and data, not more unsubstantiated assertions.

The four main issues: Omission, Necessity, Consistency, and Reasonableness/Realism almost always boil down to a lack of adequate documentation and substantiation as a root cause. Provide corroborating evidence to justify unit costs and rates. Clearly explain how costs were derived and/or calculated.

3.     Make it Easy for the Evaluator.

If you elect to revise your pricing, clearly track those changes in your pricing model. This is especially important when there are numerous and significant changes to price. The Government needs to understand how and why your price changed. Highlight cost elements that were added to your proposal. Identify unit cost and rates that were revised. Flag items that were removed from your revised proposal. Also ensure to provide a brief narrative summarizing what has changed in your revised proposal pricing.

 Conclusion

Breathe a little sigh of relief. Your firm has progressed through 1st cut. While your firm hasn’t won the contract (yet), the Government believes your proposal has enough merit and deems it worthy enough for additional consideration.

Remember, the Government is evaluating MANY proposals in addition to your proposal. Contracting officers want to progress to contract award, now ! Help them by clearly, accurately, comprehensively responding to evaluator pricing questions. Give the evaluators the missing pricing facts and data they need so they can demonstrate they evaluated your winning proposal objectively, fairly, and consistently.


About the author:  Mike Gallo is Partner and Principal Consultant at Federal Pricing Group, a consulting firm focused on providing expert contracts pricing to small and mid-sized federal government contractors and cost-related acquisition support services to federal agencies. Learn more at https://www.federalpricinggroup.com/.

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