DHS Insight: The GSA-DHS OASIS MOU – A Game-Changer in DHS Contracting

on Oct 30, 2015 in Acquisition, DHS | 0 comments

FlagThe GSA-DHS OASIS MOU – A Game-Changer in DHS Contracting

What are the terms and impact of the OASIS MOU? Under the DHS-GSA Memorandum of Understanding (MOU) regarding OASIS signed in July, DHS expects to increase its contract awards under OASIS from $11 million in 2015 to between $200-$250 million in 2016. Under terms of the MOU, GSA agreed to lower the contract access fee from 0.75% to 0.25%, and DHS in turn agreed to include OASIS as one of its “Strategic Sourcing” contract vehicles covered under its “Mandatory for Use” Management Directive. So what does this mean for OASIS and EAGLE II Prime Contractors? Plenty.

The immediate impact will be felt by TABSS Prime Contractors. This is a huge body blow for them. With TABSS sun-setting in two years, contracting officers will immediately see OASIS as a preferred contract vehicle, fully endorsed by DHS leadership. With the ability to award program management task orders under OASIS for a full five years and only two years under TABSS, few contracting officers will see TABSS as a viable option.

The OASIS Prime Contractors now have all of DHS available to them as a preferred contract vehicle, “mandatory for use” by DHS Component contracting officers. This is a big opportunity for them, but many OASIS contractors (particularly those on OASIS SB) have little or no experience working in the DHS environment. Their ability to quickly introduce their companies and capabilities to DHS contracting officers and program managers will be critical in 2016.

EAGLE II, Functional Category 2 (FC2) Prime Contractors will also feel the impact of the MOU, just not as quickly as TABSS Contractors. With EAGLE II the competitive advantages and disadvantages are far more subtle. Understanding these advantages and disadvantages will be important for EAGLE II and OASIS contractors as they work to shape opportunities in this new, uncertain contracting environment.

Following is a point-by-point look at the key factors that will impact both EAGLE II and OASIS contractors in the coming year:

First, there is only one NAICS Code available for EAGLE II Functional Category (FC) 2. NAICS code 541512, which is specifically for IT services support, is the only NAICS Code designated for use under EAGLE II FC2. This limits the options for contracting officers considering EAGLE II. OASIS, on the other hand, offers 34 NAICS codes in seven “Pools,” including 21 NAICS codes in Pool 1 alone. NAICS Code 541512 is not available under OASIS, but the OASIS Pool 1 NAICS codes encompass a broad range of program management capabilities, which provides DHS Component COs very broad latitude in determining acquisition strategies.

Second, DHS uses decentralized ordering. This means that each Component is responsible for its own contracting, with broad discretion to make its own contracting decisions. Heads of Contracting Activity (HCAs) at each Component have full decision-making authority, and may make final determinations about acquisition strategies that DHS Headquarters could, but generally does not override.

Third, the final determination of whether or not a requirement is “IT Services” under NAICS Code 541512 is completely up to the Component CO.. At least one DHS Component – USCIS – has already opted to use OASIS for a program management requirement instead of EAGLE II Functional Category 2, determining that the work was not primarily “IT Services.”

Fourth, GSA has committed extensive resources to enhance the customer service offered for its GWAC contract vehicles.  GSA actively promotes the use of its GWAC vehicles across Federal Departments and Agencies, and argues that its enhanced customer service speeds the acquisition process, increases efficiency and reduces the risk of protests.

Taken together, these factors indicate that the DHS contracting game has dramatically changed. In the short term, the MOU has dramatically altered the DHS contracting environment for 2016. TABSS contractors must find ways to stay in the game, even with only two years remaining on the life of the TABSS contract. EAGLE II contractors must stress the unique terms and benefits of the EAGLE II contract with more than five years remaining in its period of performance. OASIS contractors must quickly adapt to the DHS contracting environment by raising their profile across DHS to demonstrate how their capabilities can best serve the DHS mission.

In short, whether you’re a current DHS contractor or new to the DHS environment, the rules have changed and everyone needs to adapt. Understanding the unique terms of these contract vehicles, as well as the tendencies of contracting officers in each DHS Component will be more important than ever in 2016. This simple MOU has changed the game for this year, and may portend even bigger DHS contracting changes for years to come.

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