Actions to take prior to CIO-SP4 release

CIO-SP4 Advisory

About a year ago (December 3, 2019 to be exact), the United States Department of Health and Human Services (DHHS) announced the recompete schedule for Chief Information Officer – Solutions and Partners 4 (CIO-SP4). The target date was late summer, early fall 2020, but most concluded that the RFP would drop at the start of the fiscal year (early October 2020).  Three months after updating the industry through a collection of well-attended industry briefs, DHHS found itself at the forefront of a national emergency: the U.S. was entering the first few stages of a global pandemic that stressed the capabilities of both public and private sector resources.  With DHHS’s Centers for Disease Control and Prevention (CDC) on the front lines in the battle against the Coronavirus, resources, budgets, and other Federal assets changed almost overnight.

The CIO-SP3 Legacy

The CIO-SP3 program represents IDIQ and subsequent Task Orders for both large and small business. In FY2019, for instance, data provided by the National Information Technology Acquisition and Assessment Center (NITAAC) suggests that annual small business spend on prime contracts to small business was $6B.  The current IDIQ runs through May 20022 and is categorized under the NAICS Code 541512. The existing program and cuts across 137 labor categories for task order in support of everything Informational Technology (IT) related and spans ten (10) task areas.

Timing of CIO-SP4

With the urgency of pandemic response responsibilities, DHHS’s focused shifted to the immediate challenge of the pandemic as did supplemental DHHS budgets, manpower, and resources.  The intensity of the pandemic response required a change in operational focus and thus the launch window for CIO-SP4 became uncertain.  The most recent guidance from the National Institutes of Health (NIH) Information Technology Acquisition and Assessment Center (NITAAC) advises that the final Request for Proposals (RFP) will be released in late November or early December 2020.  

CIO-SP4 is anticipated to be a 10-year IDIQ contract with a $40B ceiling in IT services which is double the ceiling of the current IDIQ.  Moreover the CIO-SP4 program will utilize a self-scoring methodology for evaluation and will likely require certifications (such as FedRamp) to determine overall bid eligibility.  The self-scoring worksheet for CIO-SP4 was posted via SAM.gov on September 25, 2020.

Using December 1 as the target date, RWCO forecasts that complete responses would be due back to NITAAC about sixty-days (60) after RFP release.  This puts the proposal submission window right around February 15, 2021.   Thus, RWCO’s timeline for CIO-SP4, which will be procured under one (1) single GWAC RFP, is as follows:

• September 25, 2020: Self Scoring Worksheet updated on SAM.gov
• December 15, 2020: forecasted RFP release date (estimated)
• March 31, 2021: Proposal Response Deadline (estimated)
• April- December 15, 2021: Evaluation Phase (estimated)
• December 2021: Award Notification
• May 2022: CIO-SP3 (predecessor GWAC); CIO-SP4 performance period starts (estimated)

The current draft for CIO-SP4 has been released and is available via the Beta.SAM.gov site, tagged under the Notice ID of 75N98120R00002.

Small Business Opportunities and Lessons Learned from CIO-SP3

The predecessor GWAC, CIO-SP3 was procured using two-track systems for large and small business participation. DHHS made 52 awards to large business via the “unrestricted” track and another 358 awards to small businesses.  In so doing, DHHS unintentionally created an environment in which small businesses had limited participation. When an agency decided to use the GWAC, the contracting officer at the task order level often defaulted to the unrestricted GWAC.  Thus, when a requirement was slotted into the unrestricted GWAC, the entire community of 358 small business could not see or participate in that task order opportunity.  Additional changes for CIO-SP4 are anticipated to include new technologies and processes and provide an opportunity for contracting officers to set aside task orders for women-owned businesses and other socioeconomic categories. 

Action Items Prior to RFP Release

Given the timing and emerging requirements of both self-scoring of IT capabilities/solutions, potential participants in the bidding process should take immediate action.  Small businesses may also be required to “qualify” for a minimum number of task areas. NITAAC has advised that the qualification requirements may map to as few as five (5) task areas or as many as eight (8) task areas. This requirement is one of the few final adjustments that will emerge upon RFP final release.

Small businesses seeking to enhance their competitive position may opt to take the remaining time before the final RFP to formulate teaming arrangements that expand coverage across the task areas. In doing so, Contract Teaming Agreements  (CTA) and Joint Ventures (JVs) may offer viable solution for further competitive differentiation and compliance. Contract Teaming Agreements are a bit more involved than a simple prime/sub teaming agreement and thus require the completion of certain items to pass approval during a procurement evaluation. We have experience building these CTAs and we have helped clients win work through the CTA process.

 It should be noted that  CTA’s are governed by FAR Subpart 9.6 (www.acquisition.gov/content/subpart-96-contractor-team-arrangements) and the All Small Mentor/Protégé program falls under the purview of the SBA. All Small Mentor/Protégé structures may formulate a Joint Venture through the SBA. We have experience creating these joint ventures via both the SBA and the agency-relevant Office of Small Business Development and Utilization.

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