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page limitations on proposals


contractor100

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Everyone was sitting around chatting about the most recent RFQ to cross our desks which:

Stated it was "best value" solicitation, with technical the most important of the factors

Had a 50+ page SOW, with fairly elaborate specifications

Limited the technical approach to 10 pages, 12 point type, one inch margins, double space, "graphics may contain 10 point type"

Fixed price quote.

Stated "may award without discussions."

 

We have seen at last 15 such RFQs this year, from quite a few different agencies and contracting shops. All RFQs have been task orders on GSA schedules. Some were on ebuy, some were directed to a specific group of contractors.

Anyone care to share opinions on why such RFPs are released?  

Proposals from my colleagues:

1.  So what if the specs are five times longer than the pages allowed to address them? There is no connection between detail in specifications and number of words in the technical approach. We should be able to explain how we will do this work at a general, high level in ten pages, and there is no reason that is not sufficient to make an award. 

2.  This is an RFQ. Our proposal will not be incorporated into the contract.  The government does not understand what it wants to buy and does not want to get tied down to a specific solution. They are trying to avoid contractors' getting too specific, so that they can determine what they actually want to buy after an award has been made.  Any problems with the pricing can be cured with modifications.  This is "commercial practice."

3.  Because we are on GSA schedule, they already know we know how to do the work, so we should not need to explain how to do the work in this specific instance.

4.  The government actually wants to run an LPTA competition, but people complain about LPTA competitions.  People make jokes about John Glenn/Alan Shepard and rockets built from lowest priced parts.  So by making contractors' technical approaches meaningless and therefore impossible to compare, the contract can be awarded on price -- without calling it LPTA.

5.  The contracting office is sick of reading corporate proposal boilerplate.  10 pages, 50 pages, 100 pages - it's all equally useless and unpleasant to read.  They are just trying to cut down on time and human suffering.

6.  The contracting office is only kidding:  let's just put all of our text into boxes with ten point type, make the text double column, and fix the leading so we can get twice as many words on the page!

 

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1 hour ago, contractor100 said:

Anyone care to share opinions on why such RFPs are released?  

Unfortunately, contract specialists, today, focus much more on administrative and clerical details - such as page limits, fonts size and spacing, and inputs to procurement management systems - than on the substance of the buy - conducting one-on-one negotiations on quality and pricing, and making sensible tradeoffs.

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I offer a few opinions on page limitations, font requirements, margins, etc.

1.  They are used to limit the amount that the selection board and/or selection authority will have to read.  If you had reason to believe that you would receive 10, 50, or 100+ proposals, would you set page limits?

2.  They are used to limit the amount of text from the solicitation that will be unnecessarily regurgitated in the proposal.  The selection board and/or selection authority might actually want proposals from firms that can get to the point, not waste time.

3.  Limitations grant an excuse to the selection board and/or selection authority to disqualify/reject lower priced non-conforming proposals (whether fairly or selectively done).

 

 

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I'd like to address number 3 (as a former GSA person).  Just because your company has a GSA schedule does not mean it knows how to accomplish the work specifically requested by the agency releasing that particular RFQ. GSA schedules are, by design, very high-level and vague. This is because it is impossible for GSA to know the unique requirements of every agency's numerous requests.  Therefore, it is perfectly natural and recommended that an agency contracting officer require offerors to submit something that shows they can do the work as detailed in the SOW/PWS. 

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Now I'm going to take a stab at some of the other points...

#1: If the government is already providing "fairly elaborate specifications", why would an offeror need to include specifications in their technical approach, which is what was limited to 10 pages?

#2:  Since the government included "fairly elaborate specifications", I would think that perhaps they do have an idea of what they want and how they want it done, within the variance as defined by the technical approach of the offerors.

#3: Already covered

#4: Why do you feel technical approaches are meaningless and therefore impossible to compare?  I've done many somewhat similar to this when I worked for DoD and the VA and never had any issues. As long as the TEP determines the approach is acceptable, award to the lowest price.  It sounds simple because it is.

#5: Totally agree with you on that one!  Remove the fluff and tell us how you're going to do this task order.

#6: I wouldn't advise that one!

In short, if the government truly does have elaborate specs or a well-defined PWS/SOW, all we really need to know is that your company has a sound technical approach, acceptable past performance and a fair and reasonable price (awarding to the lowest).  I have instituted in my office where an LPTA is appropriate that we evaluate the lowest offer.  If it is technically acceptable, we don't evaluate anybody else (why would we?) and we make award.

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 Agree with you on some of these points, Desperado, but not all.

First, none of these were LPTA solicitations!  They were best value, with the technical approach weighted most heavily.  

"...all we really need to know is that your company has a sound technical approach"

The "specs" to which I refer are an SOW, listing 50 pages worth of outcomes the government wants from certain professional services. The issue is:  If the government's technical requirements ("specs") take 50 pages, how can contractors explain how they will meet those requirements in 10 pages?  Many people feel that is impossible, hence the cynicism of some of the theories proposed.  

"Remove the fluff and tell us how you're going to do this task order."

Can we, in only 10 pages?  That is the issue. Yes, there is a lot of horrible gasbag writing in proposals and I am sorry for anyone that has to read it. But the 10-page limit is kind of a blunt instrument to solve the problem.  How about marking people down for bloviating instead?

"I would think that perhaps they do have an idea of what they want and how they want it done, within the variance as defined by the technical approach of the offerors."

Well that's the point.  Can they determine which, if any, contractor can give them what they want, how they want it, with these extreme page limitations?

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What scares me is the possibility of adding a #7.  The Government already knows who they want to award to and are only going through the motions.  If proposals are intentionally vague by minimizing page counts, it's easier to justify and thereby select the "winner".

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Here's an interesting GAO Protest Decision on page limitations that you may find interesting to read. It was a best value RFP to at least two fixed-price, IDIQ contracts, for a period of 5 years. The solicitation was issued as a small business set-aside, and established a minimum contract value of $2.9 million, and a lifetime ceiling of $120 million. The solicitation instructions limited proposals to 25 pages, specified the margin settings and font sizes to be used, and required that proposals be submitted electronically. (GAO Decision B-299305, Mathews Associates, Inc., March 5, 2007 http://www.gao.gov/decisions/bidpro/299305.htm).

This topic has been covered previously at WIFCON - here's an example: http://www.wifcon.com/arc/forum350.htm

I'm not a fan of page limitations in offers but I understand the argument for using them.  

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2 hours ago, policyguy said:

I'm not a fan of page limitations in offers but I understand the argument for using them.  

Does that 10 page "technical approach"  represent an "offer"  to be accepted and incorporated into the contract?

Given a 50+ page SOW, why do you need 5, 10 or 50 pages of blather cut and pasted from the contractor's last proposal?

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4 hours ago, jewettr said:

What scares me is the possibility of adding a #7.  The Government already knows who they want to award to and are only going through the motions.  If proposals are intentionally vague by minimizing page counts, it's easier to justify and thereby select the "winner".

What makes you say this? Do you have anything, aside from conjecture, to support this?

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Thanks for the case, policyguy - but I think most contractors understand that they can be thrown out for not following directions. 

Would love to see a protest that page limitations made it impossible to meaningfully evaluate offers - that's the issue, really.  And, per Napolik, make it impossible for the government and the contractor to enter into a contract under which the contractor has an obligation to offer a specific solution, see 2. above.  yes, the responses are RFQs, not RFPs.  that is just an odd artefact of the GSA schedules.  Commercial or not, contractors should have to offer some specific solution!

Of course, this complaint is very fact specific.  Yes, there are plenty of solicitations where ten pages is quite enough, despite the length of the SOW.  Believe me, shorter proposals save us money.  Even cutting and pasting reams of boilerplate has costs to contractors. Ten pages is cheaper, even where we have to put some thought (!!) into writing them.  But there are solicitations where ten pages just isn't enough and we really fail to see how the government can get the information it needs to compare offers or to enter into a contract under which the government can get what it needs without a ton of mods.  So, dark suspicions of the government's "real" goal in limiting the proposal, and yes, jewettr, of course people constantly speculate that page limitations mean the RFP's aimed at a particular contractor.   

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GeoSystems (B-413016, 2016) made the argument that 15 pages was insufficient for their tech volume. But it was a post-award protest--they'd shoved lots of their solution in other areas of the proposal and protested when the evaluation team didn't count the information. The Comp. Gen. denied the protest.

Sort of on topic (but the protest makes me laugh)--DKW Communications (B-412652.3, 2016), where the awardee fit their tech volume into the 10-page limit by significantly reducing the line spacing. It might have actually gone unnoticed if they hadn't used normal spacing in the rest of their proposal. The Comp. Gen. counted 66 lines/page in the tech volume and 44 lines/page in the rest.

 

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Guest PepeTheFrog

Ten pages means less time and effort reading, evaluating, and thinking.

As far as the disparity between the page counts, PepeTheFrog thinks the government either (a) has not considered it or (b) does not care. 

As a general principle, PepeTheFrog thinks it is foolish and frustrating to assume that government employees always act rationally, intelligently, or purposefully. 

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Have you asked the CO if they'd change it? I once worked for an agency that included similar page limitations as you are describing for all RFQ's they posted, regardless if it was for $100k grounds maintenance or a $20 million construction project. Maybe the CO just includes it out of habit.. 

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2 hours ago, contractor100 said:

 But there are solicitations where ten pages just isn't enough and we really fail to see how the government can get the information it needs to compare offers or to enter into a contract ...

Does that 10 page "technical approach"  represent an "offer"  to be accepted and incorporated into the contract?

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Okay, Napolik, it does not.  Because it is an RFQ.  

I have submitted at least 350 responses to GSA RFQs.  I have never, not once, had any post submission discussions or whatever they are called on GSA procurements.

Has anyone else?

I've had plenty post award!  Where we actually determined what work we would do.   

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1 hour ago, contractor100 said:

Okay, Napolik, it does not.  Because it is an RFQ.  

I have submitted at least 350 responses to GSA RFQs.  I have never, not once, had any post submission discussions or whatever they are called on GSA procurements.

Has anyone else?

I've had plenty post award!  Where we actually determined what work we would do.   

So, the contractor's submission isn't incorporated into the order.

In your opinion, what is the purpose of the very carefully coiffed 10 page submission?

Typically, does the contracting officer have any discussions with you affecting the quality or price of the effort reflected in your quote?

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21 hours ago, contractor100 said:

Commercial or not, contractors should have to offer some specific solution!

 

1 hour ago, contractor100 said:

I've had plenty post award!  Where we actually determined what work we would do.

So, you should have the opportunity to offer a specific solution, even though you haven't yet determined what work you would do.

I wonder if that would make sense to someone who knew nothing about Government contracting.

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On 9/14/2017 at 2:05 AM, Don Mansfield said:

What's your point? There's no support for the existence of the boogeyman, either. That doesn't mean we should go to sleep with the lights off.

Dadgummit, Don. Dead to rights.

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C100 - Didn't catch that these were trade-offs, but even so if the gov't has detailed requirements (aka "specs") shouldn't the approach be easier to write rather than harder?  You won't have to go into a lot of detail about the details as the gov't has already provided those (which sounds like an anti-performanced-based approach). How did the CO word the technical approach part of the RFQ?  I'm assuming they didn't just say, "Give me your approach and you only got 10 pages to do it".  I would hope they would have detailed what the approach should be addressing, and if so...  is it really unrealistic to think it could be done in 10 pages or less?

One would hope that the CO and requiring activity have worked together to determine an appropriate number of pages necessary to convey what they are looking for in  "the approach" and reduce the fluff that isn't necessary to make an award decision.  Without knowing more about the solicitation or requirement it's hard to just say off-hand that 10 pages is insufficient. I've awarded multi-million dollar contracts/orders with 10 pages or less and also awarded contracts/orders for less than a million and had the number of pages at 50.  I don't think there's a hard and fast rule about how many pages is appropriate.  It appears that the assumption of many is that the number is just pulled out of thin air and if that is true, it's sad.

 

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Napolik/Socrates - Honestly, in cases where ten pages are, truly, insufficient to address a long and complex statement of work, I am not sure what their purpose is!

 

In a competition open to all comers, I'd say it was to eliminate clearly insane responses--kind of like establishing a technical range.  Is that necessary though? You'd have to think most schedule contractors can write something reasonably germane - and there should be a lot fewer responses, especially where the RFQ only went to three bidders.

I have submitted at least 350 responses to GSA RFQs and been awarded a task order in maybe a third?  I have never, not once, had any discussions with a CO or anyone else about a solution/technical approach. Maybe in ten percent of cases I've had the opportunity to revise the price - without revising the technical.

Don, we are offering the solution after we have been awarded the contract.  So how was a "technical approach" evaluated - made the basis of a decision?

Desperado you are totally right.  Sometimes ten pages is enough.  But, sometimes, it is only enough to say "we will comply with the specifications" in various fancy ways.  Any bidder can do that!  Where's the evaluation?

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