GSA COMET II: What does it take to win?

GSA’s CIO Modernization and Enterprise Transformation II (COMET II) is a GSA Schedule Blanket Purchase Agreement (BPA) that will provide a streamlined approach to procuring various IT services. We will not see a point-based solicitation for COMET II, instead, GSA is going for a “show don’t tell” approach. Companies will need to convey their value through experience as well as a technical demo. With the previous solicitation being awarded as a Partial SB Set-Aside, COMET II is anticipated to follow that same award profile.

GSA provides the government with IT and Professional Services in which they develop applications and provide maintenance and modernization to current applications. Vendors pursuing COMET II will need to demonstrate expertise and knowledge in IT development and maintenance in technologies such as on-prem, Cloud, SaaS, and more.

Orders placed under the BPA will include one or more of the following overarching objectives:

  • Objective 1: Agile software development and maintenance
  • Objective 2: Solution/Application Design, Business Analysis, Development, Integration and Configuration
  • Objective 3: Data Management and Hygiene
  • Objective 4: Program Management Support
  • Objective 5: Release Management and Post-Implementation Maintenance Support
  • Objective 6: Support/Help Desk
  • Objective 7: Training and Change Management
  • Objective 8: FISMA Compliance/Cyber Security Support
  • Objectives 9: Responsible Innovation

In this article, we will explore the proposal response requirements, teaming, and what it will take for you to win. This information is based on the prior draft solicitation as well as the most recent PWS which was released by GSA on December 15, 2023.

Proposal Response & Requirements

GSA hasn’t released any updated proposal requirements for COMET II, so the best information we have to go on is the prior RFP. In the prior RFP, the offer response was divided into three volumes:

  1. Volume I – Past Experience
  2. Volume II – Technical Approach and Management Approach
  3. Volume III – Coding Challenge Exercise and Price
Volume I – Past Experience

Offerors will need to present up to three examples of relevant past performance. These projects must be relevant within 3 years of the RFQ closing date for a completed project. If the project is ongoing, it must have been in place for at least 2 years. The past performance must have a minimum value of $5M. GSA lists 11 scenarios and asks that each project reference hits as many scenarios as possible. These scenarios cover getting an ATO, migrating between legacy and modernized systems, developing APIs, sustaining micro-services, and many other areas of the IT lifecycle.

Don’t underestimate this volume! You should aim to have 3 project references that cover all 11 scenarios independently. You’re allowed to have one project reference from a first-tier subcontractor if needed. GSA only provided 15 pages for this section, or a 5 page write up per past performance reference. This presents a challenge to map your project against all scenarios in a compelling way, under the page count.

Volume II – Technical Approach and Management Approach

Volume II consists of two factors: Technical Approach, and Management Approach (again, this is based on the prior draft solicitation).

For the Technical Approach, offerors must demonstrate a solution for two subfactors: Enterprise COTS/SaaS Implementation, and Cloud-native Application Development and Support. When answering these two subfactors, offerors must also address the requirements in the PWS/SOO. This includes a minimum list of terms, the approach to end user engagement, and an example of how the offeror will advise the government on carrying out these Agile methodologies. All this needs to be written in 10 pages or fewer!

The Management Approach will (may) consist of two portions, the first being the overall philosophy of future task orders issued from the BPA, and the second a specific approach to a sample task order. In addition to this, a coding challenge exercise will be conducted with seven days given to complete.

Volume III – Coding Challenge Exercise and Price

The coding challenge will be conducted for offerors who have been chosen to advance to Step 3. If an offeror is invited to the coding challenge exercise, they will be given at least seven calendar days’ notice. These exercises will be held in-person at a GSA office in the Washington D.C. area. Offerors should aim for a high level of confidence in their performance of the coding challenge to be considered for an award.

For the pricing response, the government will provide a pricing worksheet. Failure to use the worksheet will result in the submission being non-compliant. The price quoted should be based on the offeror’s current GSA Schedule and at a discounted rate per the government’s request. Offsite rates will not be included as part of the total evaluated pricing; however, they are still requested in the pricing worksheet because the government plans to incorporate these rates in the awardees’ BPA.


In accordance with the prior solicitation, offerors were permitted to submit as a GSA MAS Contractor Team Arrangement (CTA), GSA Prime/Subcontractor arrangement, or Joint Venture – but there were restrictions. The least restrictive teaming option was a Prime/Sub, as most of the experience will come from the Prime, and GSA allowed one past performance reference to come from the sub. If pursuing as a CTA, GSA was looking to see experience of the CTA firms working together in the past to reduce risk. They want to see experience of the CTA itself, and not just the experience of the individual firms. If pursuing as a Joint Venture, GSA required experience and performance of the JV itself, and not the individual members.

Teaming on COMET II in the future is a bit unclear. This SBA ruling changed the teaming requirements, so GSA’s limitations on CTA and JV partnerships needs to be relax – at least on the SB track. Whether or not companies can include current or past projects from their teaming partners has not yet been clarified by the program office for COMET II. There was one question asked in the most recent RFI pertaining to teaming, and GSA stated that it would be clarified in the final solicitation – so stay tuned!

Evaluation Approach

Multiple awards are expected on this BPA, but GSA does not specify how many. In the prior RFP, GSA stated that they were looking for 5-7 total awards, but the current COMET contract has 21 incumbents.

The government will be evaluating past experience, technical approach, management approach, coding exercise, and pricing. GSA may use a multi-step approach to the evaluation and use a confidence rating to determine which companies should move on to the next volume. Companies will either receive a “High Confidence,” “Some Confidence,” or “Not Confident.”

Any offeror given a “high confidence” rating will automatically move to the next volume. Companies rated with “some confidence” may have the opportunity to move on the next volume, but this will be up to the government’s discretion.

Ultimately, the evaluation aims to ensure that the offeror has the necessary experience and expertise to successfully fulfill the requirements of the BPA.

What To Do Now, and What Does it Take to Win?

For most any multiple award contract, about half of the awardees don’t see any meaningful work. GSA COMET II is no different. Out of the 21 incumbents, only 8 companies have more than $10M in reported revenue. That means 60% of the awardees haven’t been able to get meaningful work. Look at some of the COMET task orders and determine if your company could compete for some of that work before looking at if you can prime the BPA. Don’t skip this step!

If you believe that your firm can be successful on COMET II post award, you then need to figure out what it takes to win a seat on the BPA. That starts with mapping your experience against the requirements, assessing your gaps, and then filling those gaps. You need to make sure that you have very solid experience against the scenarios and all areas of the PWS. If you can get past all of that, then it’s time to start preparing for the technical demonstration.

Written by Rachel Newman. Connect with Rachel on LinkedIn!

Want to discuss COMET II more? We’re happy to speak with you to see how we can help.