Overview of the COMET II Draft RFP

The CIO Modernization and Enterprise Transformation II (COMET II) by the General Services Administration (GSA) establishes a Blanket Purchase Agreement (BPA) for the advanced IT services the GSA requires for its digital transformation. This solicitation opens the door to agile, cloud-based, and secure IT systems to streamline federal procurement processes, support government mission objectives, and ultimately enhance service delivery across federal agencies.

Below, we’ll explore the key aspects of the COMET II Draft RFP, including contractor requirements, the eligibility of past performance references, subcontractor rules, and detailed proposal requirements.

Mandatory Experience and Past Performance

The COMET II Draft RFP does not restrict contracts used for mandatory experience from also being used as a past performance reference, giving offerors flexibility in demonstrating their qualifications. This is significant for contractors seeking to build a strong case for their ability to meet GSA’s requirements. Past performance references and mandatory relevant experience can overlap, allowing vendors to present a more cohesive record of their capabilities.

Notably, contractors can submit up to three contract references per category. Therefore, for those submitting proposals in multiple categories (e.g., Category A and Category B), they may present up to six total references. This ensures that offerors can showcase a diverse range of experience across various technical areas.

Role of Large Businesses as Subcontractors

The COMET II Draft RFP allows large businesses to act as subcontractors on Small Business set-asides in Category B or Category C. However, this comes with several stipulations to ensure the integrity of the Small Business designation:

  • Category C Provisions: Large businesses can be subcontractors under Category C, but the prime contractor must independently establish past performance to qualify for the award. This means that while a large business can contribute its expertise and resources, the small business prime must stand on its own merit in certain aspects of the proposal.
  • Exclusivity of Category C for Small Businesses: Only small businesses, with no involvement from other-than-small-business (OTSB) entities, can operate as prime contractors under Category C. This aligns with the RFP’s strict adherence to maintaining the small business designation for certain contract awards.
  • Past Performance Limitations: Although large businesses may participate as subcontractors, their past performance cannot contribute to the evaluation of the small business prime contractor. The RFP makes it clear that only the small business prime’s experience will be assessed in this regard.
  • Flexibility with References: There is no specific limit on the number of past performance references that can involve large businesses as subcontractors, provided the total does not exceed the limits specified in the COMET II Draft RFP.

Flexibility in Proposal Submissions

In response to the COMET II Draft RFP, offerors are permitted to submit proposals as a prime contractor once per category, with the option to propose again as part of a joint venture (JV) or contractor team arrangement (CTA) within the same category. Furthermore, a single company may participate as a first-tier subcontractor on other teams under the same category.

For small businesses, this flexibility allows for creative team configurations to maximize capabilities and resources without compromising the opportunity to lead as prime contractors.

Small Business Considerations in the COMET II Draft RFP

The COMET II Draft RFP outlines several unique provisions to encourage small business participation:

  • Category A-Group A2: Small businesses may bid as standalone primes under this small business set-aside, or as part of an SBA mentor-protégé JV in the same group, opening up multiple opportunities for qualification and participation.
  • Meaningful Commitment Letters (MCLs): If a small business is not relying on subcontractors to meet Volume I or II requirements, Meaningful Commitment Letters are not required from each first-tier subcontractor. This provision eases the burden on small businesses forming traditional prime/subcontractor relationships.
  • AbilityOne Agreement: For small businesses, an AbilityOne Formal Agreement with a Nonprofit Agency (NPA) will be necessary upon award. However, an AbilityOne Commitment Letter must be submitted alongside the proposal, underscoring GSA’s commitment to accessibility and equitable federal contracting.

Restrictions on Co-Prime CTAs in the COMET II Draft RFP

To ensure a streamlined and clear proposal evaluation process, the COMET II Draft RFP explicitly prohibits the formation of co-prime Contractor Teaming Arrangements (CTAs). This restriction mandates that only one member within any CTA can serve as the lead, effectively eliminating complications related to shared leadership roles and responsibilities. This approach simplifies the proposal structure, allowing for a more straightforward assessment by GSA evaluators.

Proposal Submissions for JVs

In proposals involving joint ventures (JVs), the COMET II Draft RFP introduces flexibility by not imposing a minimum requirement for Relevant Experience Points (REPs) that must be attributed specifically to the JV’s lead member. Instead, JV members can collectively meet the REP requirements, allowing for a more collaborative and comprehensive approach to proposal submissions. This structure empowers JV teams to draw on the combined experience of all members, thereby enhancing their overall qualification without undue restriction on individual contributions.

Use of REPs and Past Performance References

The COMET II Draft RFP introduces essential distinctions between REPs and past performance references, permitting offerors to reuse contracts across both categories as long as they only reference work that was directly completed by the offeror. By encouraging this level of transparency, the RFP reduces redundancy while ensuring that each cited contract reflects only the offeror’s contributions.

For small businesses applying under Categories B and C, the requirement for REPs mandates representation across three different technical areas. However, the past performance references within these categories can span multiple technical areas, providing offerors with the latitude to emphasize their strongest areas of experience.

NAICS Code Crosswalk and Sub Commitments

In proposals involving subcontractors, the COMET II Draft RFP requires a NAICS code crosswalk for first-tier subcontractors who submit Meaningful Relationship Commitment Letters. This helps verify that subcontractors’ experience aligns with the RFP’s designated technical areas, ensuring the accuracy of representations and improving GSA’s assessment of team capabilities.

Additionally, the RFP emphasizes that REPs need not have the specific NAICS code 541512 as long as they relate to SEWP VI in-scope codes. This opens up a broader set of projects that small businesses can use to demonstrate qualifications, accommodating varied experience across IT services.

Key Submission Elements of the COMET II Draft RFP

The COMET II Draft RFP specifies structured proposal volumes, each addressing distinct aspects of the offeror’s experience, capabilities, and approach. Here’s a brief overview:

  • Volume 1: Requires three past performance references per category, showcasing experience across a range of federal or related IT modernization projects.
  • Volume 2: Focuses on coding and user research experience, with an emphasis on human-centered design.
  • Volume 3: Details technical and management approach, with considerations for agile methodologies, security, and data management.
  • Volume 4: Includes a technical challenge, enabling the offeror to demonstrate problem-solving skills relevant to GSA’s specific requirements.
  • Volume 5: Presents pricing and administrative information, with transparency in labor rates and costs.

Offerors must ensure that these volumes are organized, concise, and fully compliant with GSA’s structured format.

Proposal Submission Process

All proposals for the COMET II Draft RFP are submitted digitally via the GSA ASSIST platform, with strict adherence to the submission guidelines. The submission must include signed certifications confirming compliance with the solicitation terms and conditions. Any exceptions must be clearly outlined to avoid proposal disqualification. Timely submission is critical, as late entries will not be considered.

For proposals under the COMET II Draft RFP, the clarity of each submission volume is vital. An organized cover page and table of contents can streamline the review process and strengthen the overall impression of the proposal.

Final Word

The COMET II Draft RFP presents a substantial opportunity for small and large businesses alike to support GSA’s mission through modern, agile IT services. By leveraging past performance, fulfilling mandatory experience requirements, and demonstrating expertise in user-centered design, cloud solutions, and data security, offerors can align their proposals with GSA’s objectives for operational efficiency and transformation. The careful attention to detail and adherence to submission requirements will be key for businesses aiming to secure this critical contract.