By Daniel P. Elkins, Mission and Installation Contracting Command Public Affairs OfficeFebruary 8, 2018
JOINT BASE SAN ANTONIO-FORT SAM HOUSTON, Texas (Feb. 8, 2018) -- Transition of contracted rotary wing aviation maintenance services at Fort Rucker, Alabama, in support of the U.S. Army Aviation Center of Excellence is underway following the Government Accountability Office denial of protests against the award by unsuccessful offerors.
Contract administration of rotary wing training and maintenance support services at Fort Rucker transferred to the Mission and Installation Contracting Command in August 2016. That same month, the MICC leadership announced an acquisition timeline for re-competing the contract which had been held by the incumbent for the previous 15 years.
MICC officials announced award of the contract Sept. 15, 2017, after a yearlong acquisition process, which was challenged by two of four offerors identified in the GAO decisions. In its Jan. 3, 2018, decision, the GAO noted the government's due diligence in exercising transparency throughout the process and upheld the contract award to M1 Support Services of Denton, Texas.
"Virtually every aspect of the source selection was challenged from one protester, some 37 different claims and sub-claims all denied," said Dean Carsello, the lead MICC contracting officer for the effort at Joint Base San Antonio-Fort Sam Houston, Texas.
Valued at an estimated $4.7 billion, the contract is for one year and up to nine option years. It is the largest acquisition executed by the MICC in its 10-year history. Administration of the fixed price, incentive firm target contract transferred Jan. 30 from the MICC headquarters to the MICC-Fort Rucker contracting office in preparation for M1 Support Services to begin full performance April 1.
Carsello said the GAO decision and DOD peer reviews found many of the team's innovations in the procurement to be best practices and recommended adoption for future procurements. Among these are the transparent communications and engagement with industry, monetization analysis for offered enhancements, source selection, and small business integration. Carsello led the team of acquisition professionals from such locations as the MICC headquarters, MICC-Joint Base Lewis-McCord contracting office in Washington, MICC Field Directorate Office and U.S. Army Training and Doctrine Command headquarters at Joint Base Langley-Eustis, Virginia, Aviation Center Logistics Command at Fort Rucker as well as the Air Education and Training Command headquarters at Randolph Air Force Base, Texas, for Air Force requirements.
Following transition of the acquisition requirement to the MICC, the contracting team spent months developing the acquisition strategy, identifying novel means to provide technical data, obtaining proposals, and evaluating those proposals as promptly as possible. The team then released the draft request for proposal and letter to industry highlighting areas for which the government was seeking feedback. That was followed by a two-day industry day conducted at Fort Rucker in October 2016 drawing 85 representatives from more than 40 small and large businesses. The team next solicited follow-on inquiries, which drew only 196 questions vice the typical 500-plus for an acquisition of this size. Those questions led to multiple requirements language revisions for clarification purposes to the eventual request for proposal, which was issued after DOD peer review approval in December 2016.
A last-minute delay resulting in major changes to the Air Force work statement almost derailed the schedule.
"It was a team effort between the MICC, Fort Rucker and the Air Education and Training Command," Carsello said. "What usually takes two months was accomplished in about 10 days, concurrent with the Army Training and Doctrine Command approving the Army requirements package."
This allowed the DOD Peer Review hold to be released quickly.
Upon receipt of proposals by March 3, the team completed reviews through the Virtual Contract Enterprise Army Source Selection Interactive Tool before briefing the source selection authority in May 2017 on establishment of the competitive range. Documentation was immediately released to offerors in the competitive range and four rounds of discussions were completed with four offerors.
"We were very open and transparent from the beginning," said Jennifer Hastedt, a team contracting officer at MICC headquarters. "We gave the offerors copies of their initial reviews and then held three face-to-face discussions and one telephonic discussion with them. While that's not the norm and we couldn't do that for all procurements, it helped with the protest, because it validated that the government opened its books and gave them everything."
Carsello added the open communication with offerors also proved valuable for the government by ensuring all of the strengths identified by offers in their revised proposals actually exceeded the requirement and were contractually binding.
"We allowed contractors to propose more value to the government and actually document changes in the solicitation," he explained. "Contractors identified enhancements that were strengths, proposed requirements document language changes, and the opportunity cost benefit. Proposals that identified saving money as a strength were reviewed as a cost reduction not a strength."
Hastedt added that prior to the final proposal revision, each offeror was provided a draft conformed contract including track changes of all requirements documentation that had been negotiated. This provided all of the proposed changes, enhancements as well as pricing.
"It was what the government believed each contract would look like if that offeror was the successful offeror. Each offer was allowed to tell us if the government missed something or got it wrong. Each offer signed the conformed draft contract prior to submitting the final proposal revision," she said, adding that the signed conformed drafts were also vital in the GAO decision because it demonstrated transparency with the offerors.
Any changes or clarification in the solicitation as a result of industry engagement or by the requiring activity were properly documented and amended as part of the solicitation on the Federal Business Opportunities website to ensure fairness in competition by all offerors.
The contracting team's monetary assessment comparison for parameters and attributes to satisfy the contract performance standards, or trade space, was another best practice identified by the DOD during one of its three peer reviews for oversight.
"While our award was based on the technical aspects being significantly more important than cost-price, we were able to give a comparison in net opportunity cost benefit value of the differences in the technical proposals to provide the source selection authority a better picture of how enhancements identified as strengths provide more than another," Carsello explained. "We monetized it using a standard rate just for perspective; it wasn't dollar for dollar trade, but recognizing in a trade-off selection, you still need to show why you're willing to pay more."
He went on to explain that this method serves as a better sourcing solution. The previous acquisition spanning 15 years was a cost-plus contract including annual flight bands for each of the eight rotary aircraft on separate contract line items. Although it incorporated an additional line item for over and above as well as positive incentives, there was no remedy for failure to perform. Contract performance now includes a projected flight program with a variance up to 7 1/2 percent in the total flight program. The team's contract analysis of the last 15 years found that while there have been adjustments by aircraft, total flight time has remained fairly stable. Through industry feedback, the team also decided to delineate two of the more complex aircraft to have a separate variance.
Approximately 3,700 students accomplish pilot training annually at Fort Rucker, accounting for about one-fourth of all Army annual flying hours. The contract also supports the Air Force's advanced rotary training mission.
"We've eliminated the 'over and above.' Each year, when a contract option year is to be exercised, TRADOC and the Air Force will identify the projected training flight plan for the coming year," Carsello explained. "If that plan falls within the variance, the contract is executed at the current negotiated price. If the flight plan falls outside of the variance, the contractor can provide a detailed proposal for use in negotiating an equitable adjustment."
The contract also provides new innovations that translated, according to GAO, to a potential for 191,000 extra flight hours. Monetized based on the flight rate per hour of the DOD published rate for flying hours, Carsello estimates an additional $876 million in potential benefit to the DOD. It also includes a disincentive to eliminate risks associated with improper staffing and the failure to meet the threshold of daily performance metrics. He added that the disincentive forced offerors to provide more realistic pricing and profit projections.
Hastedt anticipates that the contract administration to be more stress-free as it eliminates the guessing game of what the evaluation or proposal writing teams meant. "It's what's on the contract, and that's it."
Executing an acquisition of this size fell on a relatively small team made up of shareholder representatives and supported by a steering committee of leaders. Less than 10 dedicated personnel solicited and awarded this contract in nine months while conducting two full phases of DOD peer reviews. Teamwork was essential particularly in the small business subcontracting review.
"Also important was that small business was integrated with the technical, cost and past performance teams, and that the contractors had to update their small business participation plans five times during negotiation," Carsello said. "The small business specialist was in every negotiation and negotiated hard to get the best deal by forcing contractors to really think about what they were doing and justify it."
Over the year, the team logged in a lot of overtime to prevent the necessity of a bridge contract. It also substantially reduced costs for travel with the use of VCE-ASSIST.
"ASSIST requires that every finding goes through the writer, the sub-chair, the chair, the contracting officer, the lawyer and back to the contracting officer," Carsello said. "Our lawyer at MICC Office of Counsel, Bruce Topletz, reviewed more than 450 individual evaluation notices and findings during the month of May 2017, an enormous amount of work in the electronic process. He read them and gave us feedback, which was essential in allowing us to go into discussions more efficiently."
By meeting acquisition milestones, the team awarded the contract during the period of performance by the incumbent contractor while also preserving 100 days for the protest defense. A protest occurred and yet the transition time of 75 days currently underway will allow full performance without further sole source extension to the incumbent.
Hastedt cites the steering group for allowing the team to efficiently move past the typical delays associated with a solicitation and proposal. Made up the MICC commanding general and key leaders and executives at TRADOC, USAACE, Aviation and Missile Command, and the Program Executive Office at Redstone Arsenal, the steering group was responsible for reviewing the requirement, funding support and acquisition management.
"We had enough buy-in at the top levels that we were able to get through the red tape that we'd normally have to get through with minimal delay," Hastedt said. "Both the government and industry understood the importance of maintaining a published schedule."