RGCI - Acceptable Estimating System - NITAAC CIO-SP4 Points Scoring

The National Institutes of Health Acquisition and Assessment Center (NITAAC) released its long-awaited Request for Proposal (RFP) for the Chief Information Officer – Solutions and Partners (CIO-SP4) program on May 25, 2021. Phase I of the evaluation of offeror proposals will consist of validation of the offeror’s completed self-scoring sheet and ranking the offerors based on this scoring. Only the highest rated offerors will advance to phase 2 of the evaluation. Accordingly, every point counts!

As part of the self-scoring, Section L.5.2.7, Row 14 Acceptable Estimating System, the offeror can award themselves 300 points for an acceptable estimating system. However, to receive these points, the offeror will be required to provide proof that their estimating system is acceptable. Per the RFP, “documentation that prove the offeror has an acceptable estimating system include official audit reports from DCAA, DCMA, other cognizant federal agency, third party CPA, or an official letter from any of these that verifies the acceptability of the estimating system [emphasis added].”

Unless the offeror has already been audited, the only option likely to be open to the offeror in the time remaining before the proposal must be submitted is an official letter from a third-party CPA. There is virtually no way that a full audit could be performed prior to the proposal due date and it is the only option that would allow for a more limited review to determine the acceptability of the estimating system. DCAA and DCMA are unlikely to provide such a letter and will only perform effort at the request of the Contracting Officer.

Some good news for offerors proposing under teaming arrangements or joint ventures, only one member of an offeror’s CTA/JV or an affiliate is required to have an acceptable estimating system.

As a National Institute of Health (NIH) contract, technically, the contract awarded will not be subject to the Department of Defense (DoD) business system requirements contained in DFARS 252.215-7002 Cost Estimating System Requirements; however, the RFP specifically includes all of the estimating system adequacy criteria included in DFARS 252.215-7002 (d)(4).

Per the RFP, “Acceptable estimating system means an estimating system:

(1) Is maintained, reliable, and consistently applied;

(2) Produces verifiable, supportable, documented, and timely cost estimates that are an acceptable basis for negotiation of fair and reasonable prices;

(3) Is consistent with and integrated with the Contractor’s related management systems; and

(4) Is subject to applicable financial control systems.

An acceptable estimating system accomplishes the following functions:

(i) Establish clear responsibility for preparation, review, and approval of cost estimates and budgets;

(ii) Provide a written description of the organization and duties of the personnel responsible for preparing, reviewing, and approving cost estimates and budgets.

(iii) Ensure that relevant personnel have sufficient training, experience, and guidance to perform estimating and budgeting tasks in accordance with the contractor's established procedures.

(iv) Identify and document the sources of data and the estimating methods and rationale used in developing cost estimates and budgets.

(v) Provide for adequate supervision throughout the estimating and budgeting process.

(vi) Provide for consistent application of estimating and budgeting techniques.

(vii) Provide for detection and timely correction of errors.

(viii) Protect against cost duplication and omissions.

(ix) Provide for the use of historical experience, including historical vendor pricing data, where appropriate.

(x) Require use of appropriate analytical methods.

(xi) Integrate data and information available from other management systems.

(xii) Require management review, including verification of compliance with the company's estimating and budgeting policies, procedures, and practices.

(xiii) Provide for internal review of, and accountability for, the acceptability of the estimating system, including the budgetary data supporting indirect cost estimates and comparisons of projected results to actual results, and an analysis of any differences.

(xiv) Provide procedures to update cost estimates and notify the contracting officer in a timely manner throughout the negotiation process.

(xv) Provide procedures that ensure subcontract prices are reasonable based on a documented review and analysis provided with the prime proposal, when practicable.

(xvi) Provide estimating and budgeting practices that consistently generate sound proposals that are compliant with the provisions of the solicitation and are adequate to serve as a basis to reach a fair and reasonable price.

(xvii) Have an adequate system description, including policies, procedures, and estimating and budgeting practices, that comply with Federal Acquisition Regulations.”

Redstone Government Consulting, Inc. stands ready to perform estimating system assessments (non-audit) to determine if the estimating system acceptability requirements in the CIO-SP4 RFP and provide appropriate letters where acceptable or provide other services in support of the proposal. We recommend that contractors act quickly as the proposal deadline is fast approaching.

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Written by Redstone Team

About Redstone GCI

Redstone GCI is a consulting firm focused on fulfilling the needs of government contractors in all areas of compliance. With a singular mission to help contractors through the multiple layers of “red tape,” we allow contractors to focus on what they do best – support their mission with the U.S. Government. We are home to a group of consultants made up of GovCon industry professionals, CPAs, attorneys, and retired government audit and acquisition professionals.

Our focus and knowledge of audit and compliance functions administered by DCAA and DCMA will always be at the heart of what we do. However, for the past decade, we’ve strategically grown to support other areas of the government contractor back-office with that same level of focus and expertise. We’ve added expertise in contracts management, subcontract administration, proposal pricing, various software systems, HR and employment law, property administration, manufacturing, data analytics/reporting, Grant specialists, M&A, and many other areas. When we see a trend in the needs of contractors, we act to ensure we can provide the best expertise in the market to fulfill those needs.

One thing our clients can be certain of is that with the Redstone GCI Team in your corner, there is no problem too big and no issue too technical for our team to tackle.

Topics: Proposal Cost Volume Development & Pricing, DFARS Business Systems, Estimating System Compliance