The Federal Acquisition Regulations, most referred to as FAR, plays a significant role in GovCon Contract Professionals and Acquisition Professionals work. The FAR outlines the procurement process, ensures fair access, and protects against fraud, abuse, waste, etc. Often, contracting officers are subject matter experts on the FAR clauses, solicitations, and provisions.
For those new to the FAR—FAR Subpart 2.101 defines a clause as, “a term or condition used in contracts or in both solicitations and contracts and applying after contract award or both before and after award”. Additionally, a solicitation or provision is described as a “term or condition used only in solicitations and applying only before contract award". In the federal marketplace, we’ve become accustomed to working with solicitations where close to all FAR clauses except a few provisions are incorporated by reference only. You may believe that this is not a problem because that approach saves space and speeds up the proposal review process—and saves trees! Although, this practice does display some challenges to be examined.
This practice tends to make response teams focus on the remaining hundreds of pages worth of schedules, requirements, instructions, evaluations, and other attachments that are provided in full detail.
Therefore, in your proposal or gate review you can positively declare: "Yes, I have read the entire RFP!" However, after declaring this ask yourself these quest
- How about Section I?
- How much time are you devoting to finding and reading the full text of each clause referred to in the RFP?
- If not all of them, do you at least read the full text of those that may increase the risk of performance or those that contain some reporting requirements or proposal instructions?
- How would you know which clauses have such constraints and requirements without reading them in full text in the first place?
We wanted to know for our own education how many additional pages an RFP might be if all clauses and provisions were included in full text. To determine, we used the FARclause.com database to extract all clauses from a random IDIQ RFP that we pulled from SAM.GOV.
The program is called "The Global Solutions Management - Operations (GSM-O) II” and the RFP number is HC102SISR0024. According to the document this is a recompete of the HC102S-12-D-0021 IDIQ. The RFP for this program, not counting all the attachments, is 276 pages long—that’s a lot of pages to review! It also has 344 FAR, DFARS, and Army clauses and provisions—28 of which are provided in full text. Not counting those 28 full text clauses that span across 33 pages, how many pages would this RFP contain if all the clauses were published in full text?
The answer is 615 pages—the number of RFP pages would more than double!Now go to your proposal review meeting and tell them that you have read the entire RFP! Unison’s FAR compliance solution—FARclause, provides improved proposal development. FARclause.com helps professionals to understand which FAR clauses are mandatory and which ones can be negotiated out. Ensuring that every FAR clause in the RFP is accounted for, not just those listed in Section I.
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