Army Instructional Support Proposal Gap Analysis for FAR/DFARS

Non-personal services nature of requirement

States: “This is a non-personal services contract to provide Instructional Support for the U.S. Army” and reinforces COR/CO roles

Explicitly acknowledges non-personal services; commits to avoid employer-employee relationship; mentions DFARS 252.201-7000 boundaries

Covered

Good alignment; could further define how personal services indicators will be avoided (government direction, scheduling control, tools).

CLIN 0001 Instructional Support Services (FFP) — provide management/supervision/labor per PWS

CLIN 0001: provide all necessary management, supervision and other labor to perform per PWS; FFP

Provides technical approach, program manager role, staffing stability, QC approach; references PWS alignment

Partially Covered

PWS details are not included in provided excerpt; no staffing table, labor categories, quals, or hours mapping shown—evaluation risk if required elsewhere.

CLIN 0002 Service Contract Reporting (FFP) — PWS 5.6 content + due by Oct 31

Requires SCR including composite direct/indirect/relevant/avg hours and value+comp; FY Oct–Sep; report by Oct 31

Commits to SCR per PWS 5.6; repeats data elements and timing; describes internal labor tracking

Covered

Strong; could add the exact system/portal, roles, and validation steps if PWS specifies.

CLIN 0003 Travel (FFP; reimbursed NTE; approved by COR; JTR/FAR 31.205-46)

Travel reimbursed IAW JTR and FAR 31.205-46; must be approved in advance by COR; NTE amounts by year

Acknowledges approval in advance; JTR/FAR 31.205-46; includes base/OY NTE amounts; documentation and audit readiness

Covered

Consider clarifying invoicing method for travel in WAWF (separate line/attachments) if needed.

CLIN 0004 Surge/MTT (FFP; NTE; 30 days notice; written approval; funding)

Requires MTT capability away from Ft. Gordon; CO or COR approves; no performance without prior notification, written approval, and adequate funding; 30 days notice; NTE amounts by year

Acknowledges 30 days notice; written approval/funding; maintains surge-qualified pool and playbook; cites NTE amounts

Covered

Could add readiness metrics (response time, staffing lead time) and how funding authorization is confirmed.

Option CLINs 1001–2004 periods and same CLIN requirements

Option year CLINs mirror base; periods 06 Jul 2027–05 Jul 2028 and 06 Jul 2028–05 Jul 2029

Proposal acknowledges base and both option periods and includes option-year NTE amounts

Covered

Add explicit commitment that option CLIN pricing will be provided per schedule (already stated generally).

Period of Performance (base and options)

Base 06 Jul 2026–05 Jul 2027; OY1 06 Jul 2027–05 Jul 2028; OY2 06 Jul 2028–05 Jul 2029

Explicitly restated with transition readiness; start date commitment

Covered

No gap.

Service Performance Site DoDAAC W58MUV (performance site identifier)

Performance site listing includes DoDAAC W58MUV

Not mentioned

Gap

Low/Medium: may be required for WAWF receiving/acceptance or coordination; omission could cause admin friction.

FOB Destination / delivery terms

SF1449 indicates FOB Destination unless otherwise marked

Not addressed

Gap

Typically low for services; but if any deliverables/training materials are shipped, terms matter.

PSC/NAICS identification

PSC U008; NAICS 611430

Acknowledges NAICS 611430; PSC not mentioned

Partially Covered

Usually minor; add PSC acknowledgement if solicitation expects it.

G-01

Small Business Subcontracting Plan

FAR 52.219-9 (checked in 52.212-5 list) + addendum listing 52.219-9 (Alt II)

No subcontracting plan, goals, eSRS reporting approach, designated SBLO, make-or-buy, or good-faith effort narrative

May render offer noncompliant or score poorly; post-award compliance exposure

High

G-02

Limitations on Subcontracting (LOS) approach

FAR 52.219-14 (checked)

No explicit commitment that prime will perform required % of personnel costs; no staffing split prime vs subs

Eligibility/compliance risk for set-aside; potential termination/penalties

High

G-03

Cybersecurity compliance specifics (CUI/CDI)

DFARS 252.204-7012; DFARS 252.204-7008; addendum 52.240-93/52.240-91

No NIST 800-171 alignment statement, SSP/POA&M posture, SPRS score/process, incident reporting SOP, subcontractor flowdown confirmation

Material performance and compliance risk; could affect award responsibility

High

G-04

Representations/certifications not explicitly addressed in narrative

FAR 52.203-11, 52.203-18, FAR 52.229-11, DFARS 252.204-7017, etc.

No explicit statement that required reps/certs are completed in SAM/attachments; no crosswalk list

Administrative non-responsiveness risk depending on solicitation instructions

Medium

G-05

Antiterrorism Awareness Training

DFARS 252.204-7004

No commitment to complete AT awareness training prior to performance/access

Installation access delays; noncompliance finding

Medium

G-06

WAWF receiving report / Appendix F awareness

DFARS 252.232-7006(f)(5)

No statement ensuring Invoice 2-in-1 content meets receiving report requirements; no acceptance workflow description

Invoice rejects/payment delays; admin friction with COR

Medium

G-07

Service Performance Site identifiers

Performance site DoDAAC W58MUV (schedule section)

Not referenced; no plan to confirm site POC/address details

Coordination/acceptance friction; minor risk

Low/Medium

G-08

Detailed staffing qualifications mapping to PWS

CLIN 0001 references PWS; implied evaluation expectation

No resumes, quals, labor category mapping, hiring pipeline, substitution process

Technical evaluation weakness; performance risk perception

Medium

WAWF registration prerequisites

Must have designated electronic business POC in SAM and be registered in WAWF

States intent to use WAWF; mentions SAM maintenance and keeping E-Biz POC current

Partially Covered

Does not explicitly commit to WAWF registration steps/training; may be assumed but better to state account readiness.

Document type selection

For fixed-price services no shipment: Invoice 2-in-1 (or as CO specifies)

Commits to Invoice 2-in-1 “when applicable/when directed”; repeats services context

Covered

Good.

Routing Data Table values

Pay Official HQ0490; Issue By W91249; Admin W91249; Service Approver/Acceptor TBD; other fields blank

States Pay Official HQ0490; Issue By/Admin W91249; will coordinate to input Service Approver/Acceptor once designated

Covered

Does not mention other routing fields (Inspect By/Ship To/etc.)—likely N/A for services but could note “blank unless directed.”

Receiving report requirements

Receiving report must meet DFARS Appendix F requirements

Not mentioned

Gap

Medium: could affect acceptance workflow if separate receiving report is required or if 2-in-1 must meet receiving report content.

Payment request documentation sufficiency

Payment request must include documentation appropriate to type per payment/financing clause

States each payment request will include appropriate documentation and accurate CLIN/POP/amounts; will resolve rejects

Partially Covered

Could specify typical attachments (approved travel auths, receipts, SCR deliverable, COR acceptance) to prevent rejects.

WAWF training / practice site

Clause recommends training and practice site use

Not mentioned

Gap

Low: not mandatory wording (“should”), but helpful for credibility.

WAWF POC details

Contracting activity WAWF POC is TBD; helpdesk provided

Not mentioned

Gap

Low: informational.

FAR 52.212-1 Instructions to Offerors

Solicitation provision

Proposal formatting/submission instructions, addenda, etc.

General statement will comply with FAR/DFARS; no explicit acknowledgment of submission instructions

Gap

Medium: if 52.212-1 requires specific representations, technical volumes, or addenda responses not shown here.

FAR 52.212-4 / 52.212-5 (Deviation versions)

Contract clauses

Commercial terms; statutory EO requirements; flowdowns; audit access in 52.212-5(d)

States intent to comply with FAR 52.212-4 and -5 and applicable deviations/addenda; mentions subcontract flowdowns generally

Partially Covered

Does not address 52.212-5(d) record access/retention explicitly; no flowdown list/process.

DFARS 252.232-7006 WAWF Payment Instructions

Contract clause (full text)

Use WAWF, correct doc type and routing, documentation

Addressed in invoicing section with routing data

Covered

See receiving report gap above.

DFARS 252.204-7012 Safeguarding CDI and Cyber Incident Reporting

Contract clause

Implement required safeguarding; report cyber incidents; potentially NIST SP 800-171 alignment via 7012/800-171 ecosystem

Commits to comply; states will manage systems with appropriate controls; mentions CUI handling and authorized systems

Partially Covered

No mention of NIST SP 800-171, SPRS score, incident reporting timelines/process, media preservation, subcontractor flowdown—compliance risk.

DFARS 252.204-7008 Compliance with Safeguarding CDI Controls (provision)

Solicitation provision

Representation/assurance of implemented controls (ties to 7012/800-171)

Not mentioned

Gap

High: missing explicit representation/approach may be disqualifying depending on solicitation instructions.

DFARS 252.204-7024 Supplier Performance Risk System notice

Solicitation provision

Notice regarding SPRS use in evaluation/monitoring

Not mentioned

Gap

Low/Medium: informational but can affect evaluation narrative; address awareness.

DFARS 252.204-7017 / 7018 covered defense telecom prohibition + representation

Provision/Clause

Represent whether covered telecom will be provided; review excluded parties; avoid prohibited items/services

Proposal states will comply with prohibition and align selections with DFARS 252.204-7018; does not provide the 7017 checkbox-style representation

Partially Covered

Add explicit representation outcome (will/will not provide) consistent with SAM reps.

FAR 52.204-27 ByteDance covered application prohibition

Clause

Prohibits covered application use on govt info systems etc.

Explicitly acknowledges compliance

Covered

Could add internal enforcement mechanism (MDM, policy) for strength.

FAR 52.224-3 Privacy Training (and Alt I listed)

Clause

Ensure privacy training for personnel when applicable

Commits to ensure personnel complete required privacy training

Covered

Add tracking/records retention method if desired.

FAR 52.204-7 SAM Registration (provision) + 52.204-13 SAM Maintenance (clause)

Provision/Clause

Maintain SAM registration; keep info current

States will maintain active SAM registration and keep eBiz POC current

Covered

No gap.

FAR 52.204-9 Personal Identity Verification

Clause (addendum)

PIV, credentialing/access processes

Commits to support PIV and coordinate credentialing early; onboarding includes background checks/access prerequisites

Covered

Could specify typical artifacts (I-9/E-Verify if applicable, JPAS/DISS if needed) but not required.

FAR 52.219-9 Small Business Subcontracting Plan (checked in 52.212-5 list)

Clause

If other-than-small or as applicable: requires subcontracting plan, goals, reporting (eSRS)

Proposal mentions subcontract flowdowns generally; no subcontracting plan/goals/process

Gap

High: if clause is applicable/checked, absence of plan is a major compliance/evaluation deficiency.

FAR 52.219-14 Limitations on Subcontracting (checked)

Clause

Requires prime to perform required % of work for set-asides (services typically 50% of personnel costs)

Not addressed

Gap

High: must explain how prime will meet LOS, especially if using subs/instructors.

FAR 52.219-8 Utilization of Small Business Concerns (checked)

Clause

Encourage use of small businesses; flowdown when offering further subcontracting

Not addressed beyond generic flowdowns

Gap

Medium: typically addressed with supplier outreach approach.

FAR 52.222-50 Combating Trafficking in Persons (checked)

Clause

Compliance program elements; reporting; policy; training as required

Acknowledges compliance

Partially Covered

No description of policy, awareness training, reporting channel, recruitment fee prohibition—add for strength.

DFARS 252.204-7004 Antiterrorism Awareness Training

Clause

AT awareness training for contractor personnel

Not mentioned

Gap

Medium: training requirement often enforced at installation access.

FAR 52.203-19 internal confidentiality agreements prohibition; FAR 52.203-18 representation

Clause/Provision

No prohibited NDAs; represent compliance

Not mentioned

Gap

Medium: representation may be required in offer package.

FAR 52.203-11 Certification re lobbying

Provision

Certification/disclosure re payments to influence federal transactions

Not mentioned

Gap

Medium: required certification can be a responsiveness issue.

FAR 52.229-11 Tax on Certain Foreign Procurements—Notice/Representation

Provision

Represent foreign person status; W-14 if applicable

Not mentioned

Gap

Medium: representation may be required in offer package.

FAR 52.217-8 / 52.217-9 Options

Clauses

Government option rights; notice periods; extension limits

Acknowledges preparedness to continue under -8 and -9 at specified rates/periods

Covered

Good.

52.240-93 Basic Safeguarding of Covered Contractor Information Systems (addendum)

Clause (addendum)

Basic safeguarding requirements (separate from 7012)

Proposal mentions “basic safeguarding measures consistent with applicable contract requirements”

Partially Covered

No explicit acknowledgment of 52.240-93 by number; clarify applicability and implementation.

CLIN structure and NTE acknowledgment

CLIN 0003/0004 NTE ceilings by year; travel/surge controls

Correctly cites base and option NTE amounts; emphasizes approvals and funding

Shows attentiveness to cost ceilings and authorization controls.

SCR timing and data elements

CLIN 0002 + FY timing + Oct 31 deadline

Restates requirement precisely; adds internal tracking approach

Reduces government admin burden; lowers compliance risk.

Non-personal services boundaries and COR/CO roles

Non-personal services statement; DFARS 252.201-7000 COR

Explains channels for direction and escalation; program manager as SPOC

Reduces personal services risk; improves governance credibility.

WAWF routing data awareness

DFARS 252.232-7006 routing table fields

Includes Pay Official/Issue By/Admin DoDAACs and TBD service approver/acceptor plan

Reduces invoicing errors and payment delays.

Options readiness

FAR 52.217-8 and 52.217-9

Explicit readiness to continue performance if exercised

Supports continuity and reduces transition risk.

Offer deemed noncompliant due to missing subcontracting plan

52.219-9 checked/required but plan not provided

Medium

High

High

Add a complete Small Business Subcontracting Plan (incl. goals, SBLO, eSRS cadence, good-faith procedures, flowdowns) or explicitly justify non-applicability (if prime is small and clause not applicable per solicitation instructions).

Set-aside compliance failure (LOS)

No documented plan to meet 52.219-14 for services

Medium

High

High

Add LOS compliance statement and staffing/subcontract cost model proving prime will meet % personnel cost requirement; include controls to monitor LOS monthly.

Cybersecurity responsibility determination concerns

Lack of explicit 7012/7008/NIST/incident process details

Medium

High

High

Add CUI/CDI handling approach, NIST SP 800-171 implementation posture, SSP/POA&M governance (if applicable), incident reporting SOP aligned to 7012, and subcontractor flowdown/control verification.

Payment delays due to WAWF acceptance/receiving report issues

Invoice 2-in-1 may be rejected if not meeting Appendix F or if routing fields wrong

Medium

Medium

Medium

Add WAWF process steps, internal checklist, and coordination plan for Service Approver/Acceptor DoDAAC assignment; confirm receiving report data elements.

Mobilization delays due to training/access requirements

AT awareness training and PIV/access not fully enumerated

Medium

Medium

Medium

Add a compliance training matrix (AT, privacy, trafficking, cyber) with tracking method and pre-start completion commitment.

Insert a Requirements Compliance Matrix (RCM)

CLINs 0001–0004; WAWF clause; key FAR/DFARS clauses/provisions

A table mapping each requirement/paragraph to proposal section(s) and attachments; include status and notes

Improves evaluator traceability; reduces risk of overlooked compliance.

Provide (or explicitly address applicability of) a Small Business Subcontracting Plan

FAR 52.219-9 (and any alternate)

Plan with goals by socioeconomic category, SBLO designation, eSRS reporting method, make-or-buy, flowdown and monitoring

Addresses a high-risk compliance item; strengthens award eligibility.

Add Limitations on Subcontracting (LOS) compliance approach

FAR 52.219-14

Explicit LOS commitment + estimated personnel cost breakdown prime vs subs; monitoring and corrective actions

Reduces set-aside compliance risk; increases confidence in staffing model.

Strengthen cybersecurity section with DFARS 7012/7008 specifics

DFARS 252.204-7012; DFARS 252.204-7008; 52.240-93/52.240-91 as applicable

State NIST SP 800-171 alignment approach, CUI boundary, secure tooling, incident reporting steps, subcontractor flowdowns, and (if applicable) SPRS/NIST assessment posture

Reduces responsibility and performance risk; demonstrates maturity.

Add a WAWF ‘invoice-to-payment’ process and Appendix F acknowledgment

DFARS 252.232-7006(f)(5) and routing table

Checklist of required fields, typical attachments (travel approvals/receipts, acceptance documentation), handling of TBD Service Approver/Acceptor, internal QA before submission

Fewer invoice rejects and payment delays.

Add training/compliance tracking matrix for personnel

DFARS 252.204-7004; FAR 52.224-3; FAR 52.222-50; cyber handling training

List required trainings, when completed (pre-start), how tracked, and who is responsible

Reduces access delays and compliance findings.

Explicitly address key representations/certifications completion method

FAR 52.203-11; 52.203-18; FAR 52.229-11; DFARS 252.204-7017; 52.204-7/SAM

Statement that all reps/certs are current in SAM and any required solicitation attachments are included; include a reps/certs index

Reduces administrative non-responsiveness risk.

Add staffing qualifications/resume and substitution controls (if required by PWS/52.212-1 addenda)

CLIN 0001 per PWS; solicitation instructions in 52.212-1/addenda

Labor category mapping, minimum quals, resume snapshots, backfill/substitution process, surge pool quals

Improves technical rating and demonstrates readiness.