Riftur

DoD Custodial Services RFQ Proposal Compliance Gap Analysis

Solicitation NameCustodial Services - Brookville, Clearfield, and Saint Marys, PA
Solicitation LinkSAM.gov
IndustryNAICS 56 – Administrative and Support and Waste Management and Remediation Services

This solicitation is focused on custodial services performed on a DoD installation under a firm-fixed-price structure with a base year and four option years. The evaluation is price-only, so administrative completeness and pricing correctness carry outsized weight because there is little room to offset omissions with narrative strength. The results below separate what is already aligned from what could trigger rejection, ineligibility concerns, or post-award compliance exposure. The strongest themes are that the draft understands the contract framework and many operational clauses, but several “submit with offer” and “complete the provision” items are not yet evidenced in the package. The most consequential gaps are the items that affect basic responsiveness: a signed SF1449 with required blocks completed, the Prime certificate of insurance required with the offer, and replacement of placeholder POC/negotiator data with actual obligating contact information. These are not minor formatting issues; they are common administrative gate checks that can end evaluation before price is even considered. The pricing narrative also aligns to the base-plus-options evaluation method, but the absence of actual CLIN-by-CLIN unit prices and extended amounts leaves a material evaluability blocker in a price-only competition. Together, these gaps concentrate risk at the submission-package level rather than at the service approach level. A second cluster of gaps sits in representations, fill-ins, and clause acknowledgments where intent is stated but completion is not demonstrated. Missing or incomplete checkbox-style provisions (small business representations, covered telecom representations, security prohibitions/exclusions representations, and other provision “fill-ins”) can create eligibility uncertainty and slow or prevent award if the contracting office cannot confirm representations are valid at the time of quote. Labor and policy clauses that are not acknowledged, such as paid sick leave and the text-messaging ban policy, are less likely to cause immediate rejection but can surface during responsibility review or become enforceable compliance issues after award. These issues matter because they affect auditability and enforceability; they determine whether the Government can rely on the quotation as a binding, internally consistent commitment. Security-related compliance is generally positioned well for installation access in one area (annual Level I AT training), but it is weaker where the solicitation incorporates broader access and information-protection requirements. The current language about showing ID for visits does not fully substitute for explicit acknowledgment of PIV enrollment and badging obligations, which can impact mobilization and start-of-work timelines. The lack of any posture for safeguarding covered defense information and cyber incident reporting leaves a preventable compliance exposure, even if the work is “non-IT,” because incidental access to controlled information is still possible on an installation. In contrast, invoicing and WAWF routing details are notably aligned and reduce downstream payment friction, which is a meaningful strength once the submission clears responsiveness screening.

Output Analysis

This gap analysis maps explicit solicitation instructions, submission requirements, and incorporated FAR/DFARS clauses in solicitation_text.docx (Reference Criteria) against the content provided in input_proposal.docx (Draft Document). Requirements were extracted primarily from the sections titled “COMPLETING A QUOTE FOR SUBMITTAL,” attachment list, insurance requirements, Level I AT training clause, disclosure of unit price clause, WAWF payment instructions, and evaluation addendum (price-only). Each requirement was assessed for evidence of full coverage, partial coverage (stated intent without all required details/artifacts), or a gap (missing or contradictory). Particular attention was given to “must/shall” language, required submittals (e.g., signed SF1449, COI), representations/certifications that require completion, and procedural compliance items (submission method, validity period, amendment acknowledgment). Risks were assigned based on likely impact to responsiveness (non-responsive/ineligible), award risk (responsibility determination concerns), or post-award performance/compliance exposure. Because the Performance Work Statement (Attachment 0001) content is not included in the provided Reference Criteria excerpt beyond its existence and general requirement, technical-task-level compliance to PWS specifics is only verifiable at a high level (commitment statements), and is flagged as a residual verification dependency on Attachment 0001/0002-0004 details.

Bid/Quote Submission & Administrative Compliance Matrix (Responsiveness-Critical)

Requirement IDReference Criteria (solicitation_text.docx) RequirementDraft Document (input_proposal.docx) EvidenceCoverage StatusGap/Risk Notes

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.

Pricing / CLIN / Evaluation Alignment (Price-Only; Option Evaluation)

Requirement IDReference Criteria RequirementDraft Document EvidenceCoverage StatusGap/Risk Notes

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.

Insurance Requirements Mapping (FAR 52.228-5; FAR 28.307-2)

Requirement IDReference Criteria Insurance RequirementDraft Document EvidenceCoverage StatusGap/Risk Notes

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.

Performance/PWS Compliance & Technical Approach (High-Level; PWS Not Provided)

Requirement/AreaReference Criteria RequirementDraft Document EvidenceCoverage StatusGap/Risk Notes

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.

Labor, Socioeconomic, and Workforce Compliance (SCLS/SCA and EEO)

Requirement IDReference Criteria RequirementDraft Document EvidenceCoverage StatusGap/Risk Notes

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.

Security, Access, and Information Protection (PIV, AT, CDI)

Requirement IDReference Criteria RequirementDraft Document EvidenceCoverage StatusGap/Risk Notes

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.

Invoicing / Payment / WAWF (PIEE) Compliance

Requirement IDReference Criteria RequirementDraft Document EvidenceCoverage StatusGap/Risk Notes

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.

Subcontracting / Responsibility / Representations & Certifications

Requirement IDReference Criteria RequirementDraft Document EvidenceCoverage StatusGap/Risk Notes

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.

Overlap & Positive Alignment Highlights (What the Proposal Already Does Well)

Alignment AreaReference Criteria SignalDraft Document StrengthValue to Government/Evaluation

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.

Key Gaps & Risks Register (Non-Responsiveness / Compliance Exposure)

Risk IDGap/IssueLikelihoodImpactOverall RiskPrimary Mitigation (Recommendation)

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.

Actionable Recommendations to Enhance Alignment (No Timelines)

Recommendation IDRecommended Enhancement to input_proposal.docxReference Criteria Driver (solicitation_text.docx)Expected Benefit

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.

Riftur’s findings show this submission is strongest where it ties directly to performance administration, including correct WAWF/PIEE method and routing data, clear FFP base-and-option understanding, and specific AT Level I training delivery to the COR and CO. It also surfaced high-leverage omissions that can stop evaluation in a price-only RFQ, notably the absence of an evidenced signed SF1449 with the required blocks completed, missing “with offer” insurance documentation, and incomplete contact entries where placeholders remain. It highlighted an evaluability blocker in pricing: the draft references CLIN structures and continuation sheets but does not show the actual unit prices and extended amounts needed for total evaluated price across options. It further identified incomplete or unshown completion of mandatory representations and clause fill-ins (small business representations, covered telecom representations, and security prohibitions/exclusions representations), which directly affect eligibility confirmation and award acceptability. It flagged unaddressed compliance statements for paid sick leave and the text-messaging ban, plus gaps in explicit PIV acknowledgment and DFARS cyber/CDI safeguarding posture, which are higher-risk than narrative refinements because they govern enforceable obligations and audit trails. Taken together, these insights pinpoint that risk is concentrated in offer-form completeness, required attachments, and provision completion, while key operational alignment areas are already in place and less likely to drive rejection.

© 2025 Riftur — All Rights Reserved