DoD Custodial Services RFQ Proposal Compliance Gap Analysis

INS-1

Submit with offer: Prime contractor valid Certificate of Insurance meeting solicitation minimums

States will submit with offer a valid COI meeting/exceeding minimums

Partially Covered

COI not included in draft text; if omitted at submission, could be deemed non-responsive (solicitation uses 'shall submit with its offer').

INS-2

Workers’ Comp + Employer’s Liability; employer’s liability at least $100,000 (with state exceptions)

States workers’ comp and employer’s liability with at least $100,000

Covered

Does not mention monopolistic state fund exception (not necessary unless applicable).

INS-3

General liability bodily injury comprehensive form at least $500,000 per occurrence

States general liability at least $500,000 per occurrence

Covered

Reference text discusses property damage only in special circumstances; proposal adds auto property damage minimums (ok).

INS-4

Automobile liability: $200,000/person and $500,000/occurrence bodily injury; $20,000 property damage

States auto liability meets stated minimums including $200k/$500k and $20k property damage

Covered

Aligned.

INS-5

Maintain coverage through base and option periods; provide updated certificates upon renewal/change

States will maintain through base/options and provide updated certificates ensuring no lapse

Covered

Good.

SUB-1

Offers due by SF1449 Block 8 date/time; submit via email to Contract Specialist + Contracting Officer

States will submit via email to Contract Specialist/CO by due date/time in SF1449 Block 8

Covered

No email addresses listed in proposal (not required, but can reduce clerical error risk).

SUB-2

Offer remains valid for 120 calendar days

Explicitly: “hold our offer valid for 120 calendar days”

Covered

Aligned.

SUB-3

Offeror must be registered/active in SAM for eligibility

Explicitly states registered and active in SAM

Covered

Consider adding SAM expiration/renewal confirmation statement or screenshot reference (optional).

SUB-4

Provide CAGE, UEI, TIN; and any small business preference/socioeconomic concern under applicable NAICS

States will provide UEI/CAGE/TIN with completed SF1449; states WOSB and small business concern

Partially Covered

Does not actually provide UEI/CAGE/TIN values in proposal text. If required at submission for responsiveness, omission is a risk.

SUB-5

Offerors required to complete blocks 12, 17, and 30; submit signed SF1449 Blocks 30a-30c

States intent to submit signed SF1449 (Blocks 30a-30c)

Partially Covered

No actual signed SF1449 included in draft text. If not attached at submission, high non-responsiveness risk.

SUB-6

Sign and acknowledge any solicitation amendments

States will sign and acknowledge amendments

Covered

Ensure amendment acknowledgment form/blocks included in final package.

SUB-7

Identify POC for business decisions who can obligate company; identify authorized negotiators

Provides placeholders for name/title/address/phone/email for both obligating POC and negotiator

Partially Covered

Placeholders are not actual data; if submitted as-is, responsiveness risk.

SUB-8

Complete all 'fill-ins' in provisions and clauses that apply

States will complete all applicable fill-ins

Partially Covered

No completed clause fill-ins shown; ensure final submission includes completed representations where required outside SAM.

SUB-9

Failure to provide required info may result in non-responsive/ineligible

Acknowledges non-responsiveness risk; commits to completeness

Covered

Add an internal compliance checklist appendix to demonstrate control (recommended).

SUB-10

FOIA notice: unit prices may be released; objections waived unless provided prior to submission (52.224-4001)

Explicitly acknowledges unit prices may be released; proceeds understanding waiver unless separately provided

Covered

If the offeror intends to assert any FOIA exemptions beyond unit price, must submit written objections separately prior to submission.

SUB-11

Site visit availability; visitors must show valid ID; failure to inspect not grounds for claim

Acknowledges both site visit dates; mentions ID requirement; acknowledges failure to inspect not grounds for claim

Covered

No commitment to attend is required.

SUB-12

Questions due by 12:00 PM EST Monday, 20 April 2026 to specified emails

Acknowledges deadline and intent to submit questions to CS/CO emails specified

Covered

No issues.

TECH-1

All work performed in accordance with Attachment 0001 PWS

Multiple explicit commitments to perform in strict accordance with PWS; references maps Attachments 0002-0004

Covered (High-Level)

Cannot verify against PWS task-level standards without Attachment 0001 text; residual risk of unaddressed PWS-specific methods/constraints.

TECH-2

Furnish all plant, labor, materials, equipment, supervision, transportation necessary (repeated in CLIN descriptions)

Explicitly commits to furnish all plant/labor/materials/equipment/supervision/transportation

Covered

Aligned.

TECH-3

Service frequencies: weekly/monthly/annual per facility

States will perform weekly, monthly, annual tasks for each facility

Covered

Would benefit from a crosswalk table to PWS task list (recommended).

TECH-4

Inspection/acceptance per PWS; inspection readiness

Quality control references FAR 52.246-4 and PWS inspection/acceptance framework; maintain records

Partially Covered

Does not cite DoDAAC inspection/acceptance locations (not required for proposal), but should confirm acceptance workflow aligns with COR/acceptor roles.

TECH-5

Protection of Government buildings/equipment/vegetation (FAR 52.237-2)

Explicitly acknowledges and commits

Covered

Aligned.

TECH-6

Safety of facilities/infrastructure/equipment for military operations (DFARS 252.246-7004 listed)

General safety commitments; chemical handling/hazard communication

Partially Covered

Does not explicitly reference DFARS 252.246-7004 requirements; consider adding an explicit compliance statement and how hazards/incidents will be reported/controlled.

SEC-1

Level I Antiterrorism Awareness Training: annual completion; submit certificates to COR and copy to CO (52.000-4002 and DFARS 252.204-7004)

Explicitly commits to annual completion; submit certificates to COR and copy to CO

Covered

Strong alignment.

SEC-2

Personal Identity Verification of Contractor Personnel (FAR 52.204-9) incorporated by reference

Mentions ID required for access; does not reference PIV process

Partially Covered

ID for visits is not equivalent to PIV compliance. Add explicit statement acknowledging 52.204-9 and willingness to enroll personnel in PIV/badging as required.

SEC-3

Safeguarding Covered Defense Information and Cyber Incident Reporting (DFARS 252.204-7012) incorporated by reference

Not mentioned

Gap

Even for custodial services, clause can apply if CDI is accessed/created. Add statement on limiting access, reporting cyber incidents, and NIST SP 800-171 alignment as applicable.

SEC-4

DFARS 252.204-7018 prohibition on acquisition of covered defense telecom equipment/services; related representations (252.204-7016/7017)

States will comply and will not provide covered telecom equipment/services

Partially Covered

Proposal states intent but does not provide the explicit checkbox-style representation language. Ensure the solicitation provision is completed (via SAM or attachment) in final submission.

SEC-5

Security Prohibitions and Exclusions (FAR 52.240-91 clause; 52.240-90 representations)

Mentions “security prohibitions and exclusions clauses” generally

Partially Covered

Add explicit acknowledgement of 52.240-90/91 and confirm completion of any required representations.

PAY-1

Electronic submission of payment requests (DFARS 252.232-7003)

Explicitly commits

Covered

Aligned.

PAY-2

WAWF/PIEE instructions (DFARS 252.232-7006): use COMBO/2-in-1 for services

Explicitly states COMBO/2-in-1

Covered

Aligned.

PAY-3

Use routing data: Pay Official HQ0490; Issue By/Admin W15QKN; Service Approver/Acceptor W25AR5 etc.

Lists routing data consistent with solicitation

Covered

Aligned.

PAY-4

EFT via SAM (FAR 52.232-33)

Acknowledges and will maintain banking/remittance info

Covered

Aligned.

PAY-5

Ensure payment request includes appropriate documentation; receiving report meets DFARS Appendix F (as applicable)

States invoices supported by performance documentation and internal controls

Partially Covered

Does not explicitly mention DFARS Appendix F receiving report requirements; add explicit compliance statement and what documents will be retained/submitted.

PR-1

FFP contract: 1 base year + 4 option years; evaluate total price including options; may assess option price balance

States FFP base + four options; recognizes evaluation adds options and option balance may be assessed

Covered

Good alignment with evaluation method.

PR-2

Submit price for each FFP CLIN for base + option periods on SF1449 continuation sheets

States pricing will be submitted on SF1449 continuation sheets; references CLINs 0001–0009 and option sets 1001–1009, 2001–2009, 3001–3009, 4001–4009

Partially Covered

No actual CLIN pricing values included in draft text; must be attached to be responsive.

PR-3

Pricing format must be QUANTITY * UNIT PRICE = AMOUNT/NET AMOUNT; discrepancy rules for missing unit price vs amount

States correct format and acknowledges discrepancy rules

Covered

Ensure actual continuation sheets follow exactly.

PR-4

Prices inclusive of all fuel surcharges and any other associated fees per CLIN descriptions

Explicitly states inclusive of fuel surcharges and any other fees; will not seek additional compensation

Covered

Aligned.

PR-5

Government intends award without discussions; may negotiate if price not fair/reasonable; may request additional info

States negotiator authorized to support exchanges for fair-and-reasonable price determination; recognizes evaluation addendum price-only

Covered

Consider adding a short statement offering supporting cost/price rationale (even if not required) to de-risk fair/reasonable determination.

Responsiveness framing

Price-only, responsive/responsible, meet PWS

Proposal repeatedly states intent to be responsive and comply with PWS/clauses

Reduces evaluation ambiguity; supports responsibility assessment.

Pricing inclusions

Fuel surcharges/fees included

Explicitly included and no-additional-compensation posture

Reduces risk of price disputes/change requests.

WAWF readiness

WAWF COMBO/2-in-1 + routing data

Explicitly correct routing data and method

Reduces payment processing delays.

AT training

Annual AT Level I certs to COR + copy to CO

Matches clause requirements precisely

Supports access approval and security compliance.

Insurance amounts

Meets listed minimums

Explicitly enumerates coverages and amounts

De-risks performance start/installation access.

LAB-1

Service Contract Labor Standards (FAR 52.222-41) applies; wage determination Attachment 0005

Explicitly commits to comply and apply WD 2015-4249 Rev 32 dated 12.03.2025

Covered

Good; proposal could add classification approach (labor categories) for clarity.

LAB-2

Paid Sick Leave under EO 13706 (FAR 52.222-62) incorporated by reference

Not mentioned

Gap

Clause is in solicitation; proposal should include explicit compliance statement to reduce post-award disputes/employee policy gaps.

LAB-3

Equal Opportunity for Veterans (52.222-35) and Workers with Disabilities (52.222-36)

Mentions compliance with equal opportunity requirements incl. 52.222-35 and 52.222-36

Covered

Aligned.

LAB-4

Combating Trafficking in Persons (52.222-50)

Explicitly commits

Covered

Aligned.

LAB-5

Encouraging contractor policies to ban text messaging while driving (52.226-8)

Not mentioned

Gap

Add a short driving safety policy statement and enforcement approach.

LAB-6

Prohibition on requiring certain internal confidentiality agreements (52.203-19) + related representation (52.203-18) in solicitation provisions

Not mentioned

Gap

If representation is required outside SAM or as an attachment, omission can affect responsiveness; at minimum add compliance/representation statement or confirm completed in SAM/attachments.

REP-1

Limitations on Subcontracting (FAR 52.219-14): services—no more than 50% paid to non-similarly situated; measured end of base and each option

Explicitly acknowledges 50% rule and measurement timing; states majority work by own employees

Covered

Good.

REP-2

Postaward rerepresentation (FAR 52.219-28): notify CO and update SAM upon triggering events/timeframes

Explicitly commits to comply and notify CO

Covered

Aligned.

REP-3

Small Business Program Representations (FAR 52.219-1) includes NAICS and size standard; checkbox representations may be required

Proposal states WOSB and small business concern; does not complete the representation checkboxes

Partially Covered

Must ensure the solicitation’s provision (or SAM reps) is properly completed; otherwise responsiveness/eligibility risk.

REP-4

SAM maintenance/reporting executive comp/first-tier subcontract awards (52.204-13/52.204-10)

Not mentioned

Gap

Add a brief compliance statement; if subcontracting planned, acknowledge reporting threshold awareness.

REP-5

Whistleblower rights notification (DFARS 252.203-7002) / IG office (252.203-7003)

Not mentioned

Gap

Add statement that employees will be informed of whistleblower rights and IG contact info will be posted/communicated as required.

REP-6

FAR 52.232-40 accelerated payments to small business subcontractors (if applicable)

Not mentioned

Gap

If subcontractors used, add commitment to make accelerated payments when the Government accelerates payments to the prime.

REP-7

FAR 52.204-9 PIV and FAR 52.204-19 incorporation by reference of reps/certs

Mentions 52.204-19 generally; no explicit PIV compliance statement

Partially Covered

Add explicit 52.204-9 compliance statement and confirm reps/certs are current in SAM (with date).

REP-8

26 U.S.C. 5000C tax on certain foreign procurements representation (FAR 52.229-11) if applicable

Not mentioned

Gap

If the offeror is a U.S. person, state “not a foreign person” (or confirm completion of provision) to avoid ambiguity.

R-1

Signed SF1449 and required blocks (12/17/30) not included in draft (only intent stated)

Medium

High (non-responsive)

High

Attach completed and signed SF1449; verify Blocks 12, 17, 23/24 as applicable, 30a-30c executed; include amendment acknowledgments.

R-2

COI required “with offer” not attached (only commitment stated)

Medium

High (non-responsive)

High

Include Prime COI meeting minimums; ensure dates cover anticipated POP and name/additional insured language if required by solicitation.

R-3

Placeholders for key POC/negotiator contact data

Medium

High (non-responsive/clarification delays)

High

Replace placeholders with actual names, titles, phone, email, address; ensure authority statement included.

R-4

Cyber/CDI clause DFARS 252.204-7012 not addressed

Medium

Medium-High

Medium-High

Add a CDI/cyber incident reporting posture even if minimal CDI expected; describe controls and reporting process.

R-5

PIV clause FAR 52.204-9 not explicitly acknowledged (ID mention may be insufficient)

Medium

Medium

Medium

Add explicit compliance statement for 52.204-9 and badging/enrollment process; identify responsible manager.

R-6

EO 13706 paid sick leave clause (52.222-62) not acknowledged

Medium

Medium

Medium

Add explicit compliance statement and confirm HR policy alignment for covered employees.

R-7

Driving text-messaging ban policy (52.226-8) not acknowledged

Low-Medium

Low-Medium

Low-Medium

Add a brief policy statement prohibiting text messaging while driving during contract performance.

R-8

Representations/provisions checkboxes (e.g., 52.219-1, 252.204-7016/7017, 52.240-90) not shown completed

Medium

High (eligibility/responsiveness)

High

Ensure all solicitation provisions are completed either through SAM reps/certs or included completed in submission package; add a ‘Reps & Certs Compliance’ appendix listing each provision and where satisfied.

R-9

FAR 52.203-18 / 52.203-19 internal confidentiality agreement representation/compliance not addressed

Low-Medium

Medium

Low-Medium

Add a compliance statement and confirm no prohibited NDAs are required; complete representation if required.

R-10

Foreign procurement tax representation (52.229-11) not addressed

Low

Low-Medium

Low

If U.S. entity, state not a foreign person or confirm provision completion; include W-14 only if applicable.

REC-1

Attach a fully completed, signed SF1449 (include required blocks 12/17/23/24/30 as instructed) and explicitly list included attachments in a submission checklist cover page.

Section 9(c); SF1449 note ‘Offeror to complete blocks…’; responsiveness warning

Reduces non-responsiveness risk; improves evaluator efficiency.

REC-2

Include the Prime Contractor’s Certificate of Insurance as an exhibit and restate coverage limits on a one-page insurance summary.

Section 9(f); FAR 52.228-5; FAR 28.307-2 required minimums

Meets ‘submit with offer’ requirement; avoids award delay.

REC-3

Replace all bracketed placeholders (POC/negotiator/company identity) with final legal name, address, phone, email, and an explicit statement of signatory authority.

Section 9(d) POC requirement

Avoids administrative rejection; supports communications.

REC-4

Add a ‘Representations & Certifications Crosswalk’ appendix listing each solicitation provision that requires completion (e.g., 52.219-1, 52.229-11, 52.203-18, 52.240-90, 252.204-7016/7017) and where it is satisfied (SAM or attachment).

Solicitation provisions sections; multiple checkbox provisions

Reduces risk of missing a required representation; strengthens compliance posture.

REC-5

Add an explicit acknowledgement paragraph for FAR 52.204-9 (PIV) describing how personnel will complete background/badging steps and comply with installation access controls.

Addendum clauses list includes 52.204-9

Demonstrates access readiness; reduces mobilization friction.

REC-6

Add a short DFARS 252.204-7012 statement: whether CDI is expected; if not, confirm controls to prevent access; if yes, commit to safeguarding and cyber incident reporting process.

DFARS clause list includes 252.204-7012

Reduces cybersecurity compliance exposure; supports responsibility determination.

REC-7

Add explicit compliance statements for FAR 52.222-62 (paid sick leave) and FAR 52.226-8 (no text messaging while driving) and confirm employee policy dissemination.

FAR clauses list includes 52.222-62 and 52.226-8

Prevents post-award labor/safety noncompliance.

REC-8

Provide a one-page CLIN pricing summary table (even if detailed pricing is on continuation sheets) that mirrors CLINs 0001–0009 and option years to demonstrate completeness and reduce evaluator error.

CLIN schedule; Section 9(c)-(e) pricing instructions; price-only evaluation

Improves clarity; reduces risk of missing a CLIN price.

REC-9

Include a PWS compliance crosswalk matrix (Task/Frequency/Area → Method/QA record) referencing Attachment 0001 and maps 0002–0004.

Section 6 PWS requirement; attachments list

Strengthens technical credibility and reduces ambiguity about task completion.

REC-10

Add a payment documentation/receiving report statement referencing DFARS Appendix F and internal record retention controls used to support WAWF COMBO submissions.

DFARS 252.232-7006(f)(5) and (f)(4) language

Reduces invoicing disputes and payment delays.