I want to make sure everyone reads our assessment of the latest Amendment 6 from NITAAC for NIH CIO-SP4. In addition to this summary, my colleague, Tris Carpenter, shared his interpretation of NITAAC’s update on the Mentor Protege Joint Venture (MPJV) experience now allowing two examples.
As you might have seen from the recent protest documents on the NITAAC website, there are a few outstanding items that NITAAC still needs to address with teaming. For example, NITAAC remains silent on FAR 9.601(2) teaming in M.1.1 Contract Team Arrangements despite allowing it in M.4.3 Past Performance. My interpretation is that FAR 9.601(2) is allowed and companies can form prime and subcontractor relationships for pursuing CIO-SP4, including large business subcontractors. The reason why this is important – especially in light of the issues and concerns around MPJV – is that companies that propose as a FAR 9.601(2) “may” be able to use more experience from large business subcontractors than a mentor in a MPJV arrangement.
So how does NITAAC get past this strange discrepancy while also more clearly meeting the SBA regulations that were intended to help protégé companies in a MPJV? The easiest fix in my opinion – just remove that two example limitation altogether. I understand the reasons behind why NITAAC included that limitation to begin with – they don’t want MPJV’s taking advantage of the points available in the small business categories. However, the MPJV program was intended to help small businesses that would not otherwise win on their own. What I don’t understand is why NITAAC continues to try to take on this battle since this is only pertinent to Phase 1. There will be over 1,000 small business proposal submissions regardless of whether mentor companies submit two or an unlimited number of examples. In my opinion, NITAAC should either just relax the requirement or eliminate the scoresheet altogether (let’s hear the collective industry groan). The contracts will ultimately be awarded during Phase 3 anyway, not Phase 1, where most competitive companies are already close to 10,000 points.