May 19, 2016
Diane Black
Contracting Officer
Building 705
Washington Blvd.
Fort Eustis, Virginia 23604-5538
Subject: Draft RFP Training Support Systems Enterprise (TSS-E) Mission Support Services for the U.S.
Army Training Support Command
Dear Ms. Black,
The Coalition for Government Procurement (“The Coalition”) appreciates the opportunity to respond to
the Draft RFP TSS-E Mission Support Services for the U.S. Army Training Support Command.
The Coalition is a non-profit association of firms selling commercial services and products to the Federal
Government. Our members collectively account for a significant percentage of the sales generated
through IT GWACs and other enterprise-wide contract vehicles. Coalition members are responsible for
many of the commercial item solutions purchased annually by the Federal Government. Members
include small, medium and large business concerns. The Coalition is proud to have worked with
Government officials for more than 35 years towards the mutual goal of common sense acquisition.
According to the Draft RFP, the TSS-E contract will be a multiple-award, Indefinite Delivery/Indefinite
Quantity (IDIQ) contract that provides a system of networked, integrated, and interoperable training
support capabilities for five core task areas. These support capabilities will aid active duty, reserve, and
National Guard soldiers, units, commands, and installations world-wide.
Section M.1.1. notes that the source selection will utilize the lowest price technically acceptable (LPTA)
process. Given the complex nature of the training support services asked for under the TSS-E contract, a
LPTA source selection raises significant concerns. LPTA will reduce access to best in class training
support services, limit access to innovation and increase performance risk. Rather than affording the
Army the opportunity to make a rational decision between training expertise, technology and price, and
vendors the opportunity to maximize value in the solutions they propose, an LPTA approach will incent
both sides to focus exclusively on pricing, which risks impeding access to best in class training support
services and innovation and threatens the ability of the Army’s industry partners to recruit and retain
the appropriate expertise to support Army “Readiness” objectives. In addition, this evaluation approach
will limit the ability to conduct effective, best value tradeoff competition at the task order level because
contractors at the TSS-E contract level will have been selected based on low price.
The Coalition is also concerned that the source selection and evaluation criteria outlined in the draft RFP
are inconsistent with recent Department of Defense (DoD) policy regarding LPTA. The DoD Source
Selection Procedures published on March 31, 2016 note that LPTA is not the only source selection
[process] available on the best value continuum,” and should be used only in certain circumstances.
Used inappropriately, DoD can “miss an opportunity to secure an innovative, cost-effective solution to
meet Warfighter needs.” The procedures stress that LPTA is appropriate only when the following factors
are met:
1. There are well-defined requirements,
2. The risk of unsuccessful contract performance is minimal
3. There is neither value, need, nor willingness to pay for higher performance.
In addition, implementing guidance for Better Buying Power 2.0 addresses the appropriate use of LPTA,
providing that that LPTA should only be used if the contracting officer can “clearly describe the
minimum requirements that will be used to determine the acceptability of the proposal.” Further, the
guidance stipulates that LPTA is appropriate only when the DoD “would not realize any value from a
proposal exceeding its minimum technical or performance requirements.” The memorandum goes on to
state that, “when standards of performance and quality are subjective, another approach should be
used. Professional services are often in this latter category.”
The complex TSS-E mission support services sought do not meet the criteria at the IDIQ level as outlined
in the Source Selection Procedures nor the implementing guidance for Better Buying Power 2.0. The
draft RFP lacks well-defined requirements in many areas, carries significant risks associated with
unsuccessful performance, and ignores the immense value that higher performance will inevitably have
on the Army’s level of Readiness over the next five years.
The draft RFP lacks well defined requirements. The nature of the complex TSS-E mission support
services to be provided requires a level of flexibility at the contract level. Many of the specific
requirements will need to be defined at the task order level and in response to emerging technologies in
the future, which is reflected throughout the Draft RFP. For example, clause 1.3 of the Draft RFP states,
“Any additional performance requirements, standards, and assessment measures will be detailed in
each individual task order PSW.” (Emphasis Added) Further, pursuant to clause 5.38.1, “The contractor
shall provide recommendations to modernize virtual and live simulations for individual and small unit
processes and products as identified in the individual task orders.” (Emphasis Added) Moreover, the
draft RFP uses the phrase “emerging” approximately 15 times regarding opportunities for support and
services for developing technologies and requirements as they arise. By definition, the necessity to
support such unknown opportunities is undefined.
Significant risks associated with unsuccessful performance. The Draft RFP addresses a broad scope of
complex services that will provide training and professional leader development and prepare the Army
to address global challenges. These services include vital mission and program support efforts for the
U.S. Army Training Support System throughout the world. Given the sophisticated and diverse nature of
work to be performed on such a large scale, the overall risk of unsuccessful performance cannot be
overestimated. The Chief of Staff of the Army has made Readiness the #1 priority, with increasing
quality home-station training and realistic training for National Guard Soldiers at combat training
centers (CTCs) as two of the top three focuses of this initiative. The level of training services available to
support the Army’s transition to an Army of Preparation is critical to achieving this objective.
The value, need, and willingness to pay for higher performance. In a rapidly evolving global climate,
defined by emerging threats and changing demands, higher performance for training support services
has incredible value as it is directly linked to the Army’s goal of Readiness. Given the complexity of the
services required by the draft RFP, as well as this new global environment, the MICC needs a level of
flexibility not offered by an LPTA approach which discourages innovation and best value training services
for the Army.
The Coalition recommends that the MICC identify appropriate and transparent best value evaluation
criteria to incentivize contractors to provide cutting edge, innovative solutions for the five task areas
outlined in the draft RFP. The Coalition invites the MICC to meet with our GWAC, MAC, and Enterprise
Committee to discuss the acquisition strategy. Members of the Coalition are ready to work with MICC to
identify appropriate, transparent best value evaluation criteria.
We look forward to your response.
Thank you for the opportunity to comment and if you have any questions, please contact me at 202331-0975.
Sincerely,
Roger Waldron
President