Beware the OASIS on ramp. It isn't as easy as it looks

There’s an old adage: Saying it is one thing, but proving it is another. In the world of GSA OASIS On-Ramps, this adage is very fitting.

GSA has announced that they are adding hundreds of contractors to the five OASIS Small Business and Unrestricted pools using open season on ramps. The latest schedule posted to the GSA OASIS Interact Community details the plan to move forward. OASIS Pool 1 Small Business proposals are now submitted, and in the first quarter of 2019 GSA plans to on-ramp OASIS SB sub-pools for 8(a) contractors for all pools. OASIS Unrestricted Pools 1, 3 and 4 will follow the 8(a) sub-pools, and RFPs for OASIS SB Pools 3 and 4 will round out fiscal 2019.

Contractors large and small (and mid-tier) have reacted positively and optimistically to these open season on-ramps. With all OASIS pools more than doubling in size and previous minimum scores no longer applicable during open season, many contractors believe earning a spot on these coveted GSA professional services best-in-class contracts is practically a sure thing.

Wrong.

Detailed, voluminous proof is required to back up your self-scoring. What does this mean? When contractors optimistically self-score, they often overlook the fact that their proof does not add up. In reviewing many OASIS proposals, I have observed multiple potential pitfalls to timely, complete, and compliant proposal preparation. Let’s look at a few examples.

NAICS and PSC Codes

Assume you identify five projects of the required dollar value that match the NAICS or PSC codes for your desired pool. Then, you start to look for proof. You run the Federal Procurement Data System (FPDS) reports and see that some of the NAICS or PSC codes do not match those required to qualify for the pool. What can you do? If you start early enough, perhaps you can convince the contracting officer to quietly change the code in FPDS. If no FPDS report exists, bidders can submit other verifiable contractual documents, but the FPDS report takes precedence.

However, what if you do not notice this mismatch until RFP release or the CO is reluctant to change the FPDS entry? You must wait until final RFP release at which point the CO must complete and sign the NAICS or PSC Code Correction Letter stating they erroneously reported the NAICS or PSC code in FPDS. Not many COs will willingly sign a statement saying they erroneously did anything. Or, they may not respond to your request at all, leaving little time to recover. As a result, one or more of your primary projects may no longer be acceptable.

Past Performance

Ideally, your primary projects all have a corresponding Contractor Performance Assessment Report (CPAR) with high ratings for maximum points. However, what if you do not have CPARs for your projects? You must wait until RFP release in order to send the CO or other acceptable reference the Past Performance Rating Form. You cannot start early; you must send the form included with the RFP. As we all know, obtaining signed past performance forms can take time, and you run the risk that they are not received timely or the ratings are not as high as desired.

Multiple Locations

Proving multiple locations, both CONUS and OCONUS, is tricky. Bidders receive additional points as they add up to five additional locations for each primary project. However, first, you must have contractual evidence that your staff worked on a regular basis at more than one location. Often, the contract does not specifically state that personnel are required to be physically located at separate locations on more than a temporary basis.

Second, CONUS locations must be deemed separate according to the May 2017 Metropolitan and Nonmetropolitan Area Definitions, while OCONUS are deemed separate at the metropolitan city level. You may get an unwelcome surprise when you realize that what you thought were multiple locations are actually one location. Finally, temporary duty, considered less than 30 days, does not qualify so you must be certain that the assignments are considered permanent.

Compliance, Compliance, Compliance

OASIS proposals pose almost infinite ways you can be eliminated based on a compliance issue. You have many forms to complete and much contractual documentation to provide. Missing just one box that should have been checked, failing to sign just one form, misnaming a file, or neglecting to highlight properly where the Government evaluator can find the requisite mission space, core disciplines, or annual project value can eliminate you. And, annual project values are another tricky area, as you must show accurate calculations for obligated dollars for completed projects as well as estimated dollars for ongoing projects.

It’s Not as Easy as It Seems

These are but a few of the many examples of the pitfalls involved in substantiating your self-scoring and complying fully with all RFP requirements. Many bidders under-estimate how time-consuming and difficult it is to gather all required documentation and review dozens of files for the slightest compliance issue. OASIS proposal recovery after each review can also be very time consuming as bidders must look for missing contractual documentation, follow up with COs, perhaps switch primary or secondary projects, and recalculate their scores. In addition to under-estimating the difficulties, bidders tend to over-estimate their scores. Scores typically go down once reality sets in.

None of this is meant to discourage you from seeking a spot on the coveted OASIS vehicles. Instead, be realistic. Start well in advance of RFP release not just to self-score, but also to gather documentation and identify what is missing. If you cannot gather adequate evidence, you may need to pick different projects and re-score. Seek the advice of experts to review your work and uncover all compliance issues. Conduct iterative reviews as your team completes work on each of the dozens of files. Only diligent preparation combined with the right projects, performance ratings, and certifications with adequate proof, will win you an award – assuming you rank high enough among hundreds of other competitors.