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. Now that the government has released a draft RFP, we know that we won’t 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. COMET II will be awarded as a partial small business set-aside, which is consistent with the incumbent contract. Specifically, the government intends to award at least 50% of the BPAs to small businesses.
Through the COMET II contract, GSA will continue to provide the government with IT and professional services in which they develop applications and provide maintenance and modernization to current applications. Vendors pursuing COMET II need to demonstrate expertise and knowledge in IT development and maintenance in technologies such as on-prem, Cloud, SaaS, and more.
GSA released a full draft RFP on October 17, 2024 for the overall BPA as well as 5 separate Task Order solicitations to be awarded simultaneously with the BPA award.
Orders placed under the BPA will include one or more of the following overarching objectives per the new PWS:
- Objective 1: Agile software development, modernization and enhancements
- Objective 2: Human-centered design
- Objective 3: Solution/Application Design, Business Analysis, Development, Integration and Configuration
- Objective 4: Data Management and Hygiene
- Objective 5: Program Management Support
- Objective 6: Release Management and Post-Implementation Maintenance Support
- 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.
Proposal Response & Requirements
In the recently released draft RFP, the offer response is divided into five volumes:
- Volume I – Past Experience Scenarios
- Volume II – Coding and User Research Experience
- Volume III – Technical Approach and Management Approach
- Volume IV – Technical Challenge
- Volume V – Price
Volume I: Past Experience Scenarios
Offerors will need to present up to three examples of relevant past performance. These projects must be relevant within three years of the RFQ closing date for a completed project. If the project is ongoing, it must have been in place for at least two years. The past performance must have a minimum value of $4M. 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! Your goal should be to have three project references that cover all 11 scenarios independently, or to come as close as possible to this goal. You’re allowed to have one project reference from a first-tier subcontractor if needed. GSA provided 21 pages for this section, which translates to seven pages per past performance reference.
Volume II: Coding and User Research Experience
This is a new requirement unique to COMET II. Offerors must submit one to three experience examples for two separate sample scenarios – Source Code and User Experience. Each example should be a single page with project background, problems addressed, and how the experience example is similar to the projects described in the draft RFP.
Volume III: Technical Approach and Management Approach
Volume III consists of multiple factors: BPA Technical Approach, BPA Management Approach, a SCRM Questionnaire, two mandatory Task Order responses, and three optional Task Order responses.
For the Technical Approach, offerors must demonstrate a solution for the work described in the PWS Section 5 – Functional Areas. When addressing these functional areas, offerors must address 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 of these requirements need to be written in 10 pages or fewer.
The Management Approach will 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. New to this section will also be a Supply Chain Risk Management (SCRM) Questionnaire that needs to be completed and is outside of the page count of the Management Section.
There will also be five Task Orders that need to be addressed in Volume 3:
- GSA FC3 Operations and Management (mandatory)
- IAE SAM.gov Product Architecture, Shared Services, and Developed Domains (mandatory)
- GSA – IT PMRT (Pricing and Market Research) Operations and Maintenance (optional)
- LSAM Operations and Maintenance (optional)
- IAE Acquisition 360 (optional)
Offerors are required to respond to the first two task orders and Task Orders 3-5 are optional. These task orders will be awarded in conjunction with the award of the BPA. A 10 Page Technical and Management writeup is required for each of these task orders. ricing will be provided separately in Volume V.
Volume IV: Technical Challenge
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. The only way to achieve this evaluation is through careful preparation, practice, and coaching of the team.
Volume V: Pricing
For the pricing response, the government will provide a pricing worksheet with overall BPA labor rates and pricing worksheets for the five separately awarded task orders. 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.
Teaming
Offerors will be permitted to submit as a GSA MAS Contractor Team Arrangement (CTA), GSA Prime/Subcontractor arrangement, or Joint Venture – but there are restrictions. The least restrictive teaming option is a Prime/Sub, as most of the experience will come from the Prime, and GSA allows one past experience reference to come from the sub.
If pursuing as a CTA, GSA is 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.
The draft RFP states that the Government will include in its evaluation the overall risk of the CTA Offeror’s teaming arrangement and past experience. CTAs with no prior experience working together can provide experience from their members per recent SBA rulings, but their risk evaluation will be higher than those CTAs who have performed together on similar work.
Evaluation Approach
The current COMET contract has 21 incumbent contractors. We expect the number of awards to be at least that many, if not more.
The government will be evaluating past experience, coding experience, technical approach, management approach, task order approaches, the technical challenge exercise, and pricing. GSA will use a multi-step advisory approach to the evaluation and use a confidence rating to determine which companies should move on to the next phase. Companies will either receive a “High Confidence,” “Some Confidence,” or “Not Confident.”
Any offeror given a “high confidence” rating will automatically be advised that they can move to the next step. Companies rated with “some confidence” may receive an advisory notice to move on the next phase, but this will be up to the government’s discretion. The notification after each step is advisory, and those bidders who receive an advisory notice not to proceed to the next step can still participate in the next step – but the likelihood of ending up with a BPA award are slim so bidders who receive negative advisory notices at any step should consider the costs of continuing to bid against the chances of getting an award.
What To Do Now, and What Does it Take to Win?
For most multiple award contracts, about half of the awardees don’t see any meaningful work. GSA COMET 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. Your bid decision on the COMET II BPA should include an assessment of the task orders on the incumbent contract to determine if your company could compete for some of that work.
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 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 Joe Salgado. Connect with Joe on LinkedIn!
