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Building a Robust Pricing Volume Compliance Matrix | Federal Pricing Group

  • By Mike Gallo
  • 15 Oct, 2018

What do legendary basketball coach John Wooden and federal contracts pricing have in common? Both required adherence to fundamentals. Coach Wooden focused on a simple fundamental – the proper way to put on socks and sneakers, before anything else. His premise was simple, if socks slip, they create blisters which reduces the player’s practice and ultimately diminishes game performance. In federal contracts pricing, a pricing volume compliance matrix is the equivalent fundamental of socks and sneakers. If you slip up with the pricing compliance matrix, you’re sure to put blisters on the pricing volume that can jeopardize the performance of your bid.

We all generally understand the importance of proposal compliance matrices. Given the pricing volume's complexity (which typically combines pricing, contract terms and conditions, representations and certifications, (distinctive) subcontractor pricing/data, and other business information) a compliance matrix is critical. So, let’s get back to simple fundamentals and summarize five good practices for building robust pricing volume compliance matrices.

 1.      Don’t assume proposal managers understand cost/pricing.

If you’re the pricing volume lead, it’s your responsibility to develop a comprehensive pricing volume compliance matrix. The pricing requirements listed in Section L of the RFP can be detailed, complex, and, at times, contradictory. Oftentimes, a non-expert will focus on higher level requirements and omit essential lower level details. If the proposal manager (or client) says the pricing compliance matrix is already completed, don’t argue. Just thank them, take whatever matrix they hand you, and augment the matrix with the rest of the missing information.

 2.      Capture and organize all pricing requirements.

Search and highlight all ‘shalls’, ‘musts’, and ‘shoulds’ in Section L. At a minimum, the matrix should track each requirement, the RFP section and page, and a the pricing volume section reference. Follow the RFP instructions and organize your pricing volume requirements as specified in Section L. It’s not uncommon for the RFP to contain redundant, conflicting, and poorly organized pricing requirements. If RFP does not specify the organization of the pricing volume, then align the pricing volume in the same order as the Section L pricing sections appear in the RFP. Try to group similar requirements into a logical higher-level outline item. For example, requirements related to labor rates, uncompensated overtime, Service Contract Act, work-week, etc could be grouped under a “Direct Labor” subsection. Try to strike a balance between outline breadth and depth. I prefer each section/sub-section to contain no more than 5-7 child elements. Also, carefully review the solicitation to determine if your pricing volume must include completed priced contract line items (CLINs) and other rates and ceilings from Section B of the RFP. If so, be sure your compliance matrix tracks Section B requirements too. Finally, don’t forget to carefully review Section H of the RFP for any special contract clauses that limits what the government will pay the contractor. These constraints might need to be factored into your pricing proposal. Common examples include restrictions on labor escalation and/or maximum labor rates the government is willing to pay.

 3.      Pay attention to subcontractor requirements.

Unfortunately, today, many federal government solicitations request detailed pricing information from both the prime contractor AND subcontractors. This is true regardless of whether or not the solicitation calls for certified cost and pricing data. Don’t let subcontractors become your weakest link in the pricing volume. Add extra columns to your compliance matrix to flag which pricing requirements are also applicable to subcontractors. Add an extra subcontractor column if the RFP distinguishes between ‘major’ subs and ‘minor’ subs since minor subs typically have less requested pricing detail. Plan to flow a tailored pricing compliance matrix, populated with the requirements, to your subcontractors early in the proposal process as practical to give them adequate time to meet their proposal demands. This will make your job easier when it becomes time to review your subcontractor’s pricing submissions.

 4.      Give “BOE’s” special care.

If the solicitation requires submission of ‘Basis of Estimate’, take extra care to separately track these beasts. Identify each BOE and be sure to track BOE assignments. “One BOE” is typically one Work Breakdown Structure (WBS) element out of a set of WBS elements. Sometimes it’s more complex than that. Since BOE’s are replicated across CLINs, SLINS, etc., it’s best to prepare a separate matrix that can serve as a BOE compliance checklist. Finally, be aware of hidden requirements in the form of government provided assumptions (which may not have a ‘shall’ in them). For example, if the government says, “Assume 10 locations of support.”, the compliance matrix should ensure this requirement is captured and the location of where the contractor addressed this mandated assumption. That way the government can check off assumption compliance.

 5.      Track pricing data and information requirements.

Oftentimes, other data and contractual content are included within the pricing volume. For applicable pricing requirements, identify the specific data elements/information required, the authoritative point of contact who can provide the information, completion status, and finally notes (to track specific actions taken to collect the information).

The importance of a robust pricing compliance matrix cannot be understated. Almost every RFP warns offerors that non-compliant proposals are grounds for elimination. Winning proposals aren’t just built. They are engineered. A thoroughly detailed pricing compliance matrix helps bidders limit pricing errors, omissions, and inconsistencies. Let your robust pricing volume compliance matrix be your fundamental building-block for producing a well-designed and compliant pricing volume.


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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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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