By Jeff Shen

I would like to think that Federal procurement is ever evolving, maturing, and improving. But then, we get hit with a contract like NIH CIO-SP4. This article is not intended to rehash the trials and tribulations of this primarily Federal health IT Government-wide contract[1]. The companies who responded to this solicitation know exactly just how difficult this RFP was. Even when we think we’ve seen every kind of large Federal procurement, we get thrown curveballs that force us to reconsider exactly what it takes to win.

This is not the first time we’ve been thrown a curveball in Federal procurement. When GSA first competed OASIS back in 2013, using a scorecard approach to evaluate companies primarily on their experience, past performance, and certifications, there was little information available about how to maximize points. Despite it being almost 10 years after the first scorecard proposal evaluation was introduced, companies are still learning ways they can maximize their points in the evaluation process.

Then, when the Department of Homeland Security (DHS) began competing its IT procurements using technical demonstrations and code challenges (before the Procurement Innovation Lab “PIL” made its approaches more publicly available), industry was thrown into a little bit of a tailspin trying to understand what was important to the Government during the evaluation process. These were not your typical oral presentations – these were technical “tests” to not only assess technical acumen but to gauge the ability to interact and communicate on the fly.

When NITAAC released the Draft RFP for CIO-SP4 back in March of 2020, we knew we were in for something different; not necessarily innovative or ground-breaking, just different. CIO-SP4 combined the original CIO-SP3 RFP (mostly technical written content) with a hybrid GSA scorecard approach and then incorporated a multi-phased approach to the proposal process. It proved to be overly complex, burdensome, and downright confusing for countless reasons, especially when NITAAC could not nail down its teaming requirements.

Despite these challenges, I want to say that there is a Silver Lining in Government-wide contracting and Federal health procurement. By the time of this writing, we are expecting to see an updated Draft or even Final solicitation for GSA Polaris and are awaiting updated requirements for the currently named, BIC MAC contract. Both contracts are anticipated recompetes or follow-on contracts to the Alliant 2 Small Business and OASIS contracts. GSA took the bold approach of cancelling its Alliant 2 SB contract when they realized it was outdated and they needed a refreshed look at how they were going to compete the vehicle. This led to the current concepts you see in Polaris. As for BIC MAC, as of this writing, GSA is still taking industry feedback on the most efficient way to compete this eagerly anticipated contract. What makes BIC MAC so compelling is that GSA intends to make this procurement more of an open enrollment with no cap on awardees. Further, they are considering a longer term for the contract beyond a standard 10-year Period of Performance. GSA Alliant historically has been a diverse contract and HHS/ CMS have been large users of that contract in the past. I would anticipate GSA BIC MAC to have an increasing presence in Federal health, despite its historically lower utilizations in the past.

As I mentioned in last year’s article, “What’s in Store for Best-in-Class Contracting for the Federal Health IT Community, and What Does it Mean for You?”, there is still ample opportunity, even outside of these GWACs and IDIQs for companies in the Federal health IT community. I referenced the trend of Federal health agencies moving toward using “Blanket Purchase Agreements off of GSA Schedules to provide flexibility in using a smaller subset of companies for niche requirements.” For example, since last Summer, here are just a few of the requirements that were awarded or that are soon to be awarded as a Blanket Purchase Agreement: CMS Enterprise Operations, CMS ACME, CMS DASH, HHS OIG Platform and Development, NIH NHLBI OCIO RMF, NIH Management and Consulting, NIH Financial Acquisition and Grants Management, FDA Business Transformation Team, FDA CDER Worklow Management, FDA Web Content Management System, FDA ORA eNSpect Offline Synchronization Solutions, FDA SIRCE, VA Medical Coding, DHA Enterprise Information Management, and DHA Enterprise Information Technology Services Integrator (EITSI). These are just BPA awards that were awarded this fiscal year and do not even include the numerous Federal health task orders awarded off of GSA IT-70.

I don’t see this trend slowing down, not by any means. Until NIH CIO-SP4 and GSA Polaris are awarded, Federal health agencies are limited by the available contract vehicles they can use to compete IT requirements. Yes, CIO-SP3 is still readily available with a significantly larger pool of viable vendors. However, Federal agencies have begun to express concern over the duration of the contract vehicle given that it is nearing its sunset. GSA 8(a) STARS III and VETS II remain options, but they do not have the spend or regularity of usage that other GWACs have. GSA Schedule continues to remain one of the most straightforward mechanisms to award task orders and to create “mini contract vehicles” through BPAs. While CMS and some other Federal agencies still maintain their own IDIQs, we have not seen a large increase in spend on those IDIQs. For example, in five years of performance, CMS has used less than 10 percent of its contract ceiling of $25B.

The Silver Lining moves beyond just GSA IDIQs and GWACs that have us thinking more positively in the future. Federal health agencies continue to invest in modernizing their infrastructure, systems, and applications to improve all aspects of our Healthcare including improving access to care, promoting health equity, and expediting the development of innovations to improve overall Healthcare. Fortunately, over the last three years, Federal health agencies have steadily increased their funding in digital innovation, Federal health IT investments, and major IT investments to meet their missions. Developing solutions to help the nation move past COVID is – and will continue to be – a top priority. Fortunately, for the American public and those of us in Government contracting, there are available and immediate procurement options available to expedite the competition, award, and delivery of innovative IT solutions to help us overcome any future Healthcare challenge. These options are available now and won’t require us to wait another two to three years to make them a reality.

About Jeff Shen

Jeff Shen is President at Red Team Consulting, LLC (Red Team) bringing more than 20 years of proven leadership and expertise in Federal contracting, corporate strategy, and business development. He has consulted to the U.S. Federal Government and Fortune 500 companies worldwide. Red Team is the premier provider of proposal development consulting, capture management, pricing strategy, and training services in support of Government contractors. Red Team’s mission is simple – help our clients grow their business. Visit Red Team on the web at www.redteamconsulting.com.

[1] As of the writing of this article, CIO-SP4 is still considered a Tier Three Best in Class contract which means that it meets the performance criteria for category management and is a preferred or mandatory contract vehicle for Government agencies.

Other featured articles from this year’s edition are available here.

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