6 Things You Need to Know About GSA Polaris

The highly anticipated GSA Polaris GWAC Draft RFP was released on December 31st, 2020. Intended as the next generation Small Business GWAC, this contract includes several updates meant to expand the industrial base, incorporate innovative technologies, and further support a growing base of federal customers. So, what do you need to know about GSA’s new Small Business GWAC? Our team of government contract experts, aka “the geek squad”, put together a list of the top 6 things you need to know about Polaris right now.

1. There are a lot of similarities between GSA Polaris and Alliant 2 SB. But there are also some major key differences.

One key difference is that projects are no longer based on PSC codes or Leading Edge Technologies (LETS). Projects will be based on “Primary” and “Emerging Technologies”. Primary projects will be based on NAICS codes and Emerging Technologies will be based on six technical areas instead of ten. Other key differences to note:

  • New individual score criteria for subcontracting.
  • New individual score criteria for Cloud and Cybersecurity.
  • Only three past performance required.
  • The following certifications were removed: FPRA, FPRR, Approved Billing Rates; Estimating System, and EVMS ANSI/EIA Standard-748.
  • In addition to an Organization Risk Assessment, GSA added Limitations on Subcontracting Compliance Risk, which is applicable only to HUBZones and WOSBs.
  • Cybersecurity and SCRM Assessment is required (pass/fail).
  • No price submission is required. This will be determined at the Task Order level.
2. Contractor Team Arrangements (CTAs) include FAR 9.601(1) (Partnership or JV) and 9.601(2) (Prime/Sub). There are five different ways to pursue the contract.
  • Standalone Small Business Concern
  • Small Business Joint Venture
  • Mentor-Protégé Joint Venture
  • DoD Pilot Mentor-Protégé, only if the mentor and protégé are both small
  • Small Business Teaming Arrangement (all members must be small)
3. There are differing rules for Relevant Experience, Past Performance and Systems/Certifications as it pertains to a JV versus that of a Prime/Sub relationship.

The Polaris Draft RFP currently allows for the JV or Prime Offeror with Subcontractors to use the Experience of any individual member on the team. However, for Systems, Certifications, and Clearances, the Draft RFP states that those must be in the name of the JV or in the name of every member. However, GSA will need to clarify that requirement since it conflicts with the updated (November 2020) SBA regulations on joint ventures.

For Prime Offerors with Subcontractors trying to claim credit or points for things like Systems, Certifications, and Clearances, it must be from Offeror. If you do bring on subcontractors, a Subcontractor Letter of Commitment is required for each proposed subcontractor.

4. Federal, state, local, and commercial projects are permitted for Relevant Experience and Past Performance.

However, keep in mind that Federal projects will get you more points. You can also use work that was performed as a Prime or Sub, although Prime work will also get you more points. In general, the more technically diverse individual projects you have, the more points you will receive. The same goes for a higher number of distinct federal agencies supported, individual federal task orders used as projects, and other criteria such as cost-plus and OCONUS work.

It is important to note that no projects may be used in more than one proposal for the same pool. If you use a project, do not share it with another teaming partner who wants to Prime. It’s up to you to deconflict any projects!

Key Takeaway: There will only be a single proposal submitted for all pools. A single submission means that the relevant experience can only be used once for any offeror across all submitted bids. GSA will need to clarify this, but to be safe, don’t use any project more than once for all submissions. This includes submissions as a prime and those where a company may also be a subcontractor.

5. If you have a CPARS, you must submit it.

There is a strategy to picking your past performance. If one of your past performances has a less than stellar CPARS rating, consider using one that does not have a CPARS rating yet and have your customer complete a Past Performance Rating Form. If you have no choice but to submit a negative CPARS rating, you can provide a one-page narrative to explain the challenges and how you overcame them.

6. The Risk Assessment Section is very important.

If a contractor decides to go after Polaris on their own, they will automatically get the points assigned to the Risk Assessment section. If contractors pursue the contract as a newly formed JV or as a new Prime/Sub relationship, they will not be able to claim points. GSA will be looking to see if companies have previously worked together, and their submissions will need to show proof of having worked together before, if you want to claim the Risk Assessment points. According to the Alliant 2 SB Q&A, the projects used for your Relevant Experience do not need to be the same ones used to demonstrate proof of a prior existing working relationship – we will need to see if GSA also allows for this in Polaris.

Next Steps

Before the final Polaris RFP is released later this year, there are a few things you can do to prepare. We put together three things that you can do right now.

  • Take an inventory of your projects. Create a spreadsheet to start showing how you might map your projects against NAICS and Emerging Technologies – you may quickly see gaps. After you map your projects against the score sheet, look at all the companies you’ve worked with before and consider which companies help you overcome those gaps and increase your score.
  • Consider new relationships. The final RFP won’t be out for another 6 months or so. If there are teaming partners that you don’t think will Prime, and they have a project that can increase your score (specifically in areas where a company has no prior experience), begin having initial teaming discussions. BUT don’t sign any exclusive arrangements just yet! Consider even having them work with you on an existing project to “potentially” attain your Risk Assessment score. Although, keep in mind that the final RFP may update these requirements to require more than 6 months of experience working together as a team.
  • Make a suggestion to GSA. There is still time! If there is something you want to see changed in the RFP, contact GSA and let them know by January 29th. GSA is open to comments and feedback from industry – it is in their best interest to make this solicitation as straightforward and easy to respond (and evaluate) as possible.