Increased use of GWACs affects bid process for both large and small defense contractors

Federal agencies are increasing the use of Government-wide Acquisition Contracts (GWAC) and Multiple Award Contracts (MAC) when considering defense contract solicitations. These contract vehicles allow for faster acquisition via competitive pricing and pre-qualification of sellers. As part of the pre-qualification process, “scorecard” solicitations have increasingly become the preferred method for select federal agencies to eliminate offerors from competition that do not meet perceived agency needs. These scorecards weigh numerous evaluation factors necessary to secure contract awards, such as project experience, past performance ratings, certifications, clearances and increasingly in recent history, business systems. The table below contains some basic information about various active or upcoming GWACs; click on each to find out additional detailed information:

Who can evaluate a business system? 

Acceptable, adequate, or approved? All these words may be used interchangeably within a GWAC solicitation to describe a business system requirement. While they all get to a similar idea, the official language used in DFARS 252.242-7005 is “acceptable,” defined as contractor business systems that comply with the terms and conditions of the applicable business system clauses listed above. In some GWAC solicitations, words like “adequate” or “approved” have been used in addition to “acceptable,” often in combination with requirements pulled directly from DFARS. While word choice may seem like a minor detail, it is important for contractors to understand what the customer intends with the language and requirements used in the solicitation. In particular, when “approved” is used, it begs the next question — approved by whom? 

Business system evaluations for GWAC awards can typically be performed by two parties, the government or a third-party, often limited to a CPA firm. This requirement varies by solicitation and across different business systems. For example, the CIO-SP4 solicitation accepts a review performed by the government or a third party for the accounting and estimating system requirements but will only accept a review performed by the government for the purchasing system requirement. Government reviews must be performed by a government entity, typically an administrative agency like the Defense Contract Audit Agency (DCAA), Defense Contract Management Agency (DCMA), or another federal civilian audit agency. The government will typically only perform a review when a contract award triggers the applicable requirements and is within that agency’s purview and risk profile, making this level of review difficult to obtain for many contractors. Third-party reviews are typically quicker and easier to obtain but require the contractor to pay for the services provided. The table below shows the level of approval required for recent GWACs: