Navy USNCC Proposal Compliance Gap Review for CMMC and Volume Separation

Two-volume submission (Volume I Non-Price; Volume II Price Proposal) via email attachments

Section L: submit electronically via email attachments only; two separate volumes

Volume I content present; includes a section titled "Volume II – Price Proposal (Narrative for Inclusion in Price Volume)" but no separate file separation shown

Partial

Draft mixes a price-volume narrative into the non-price document; solicitation requires separate volumes (and strictly no price info outside price volume). Ensure clean separation and file naming.

Volume I must address Phase I Institutional Characteristics + Phase II (Performance Approach, Academic Capabilities, Past Performance)

Section L (Proposal Content): Phase I + Phase II factors listed

Phase I accreditation/eligibility addressed; Phase II performance approach, academic capabilities narrative, past performance approach described

Covered

Academic Capabilities requires 1-page-per-field degree info forms; draft states intent but does not include forms/content.

Legend on each page: "Source Selection Information - See FAR 2.101 and 3.104"

Section L: each page of each copy should include legend

Legend appears as headings in sections, but per-page compliance not demonstrable from extracted text

Partial

Cannot confirm per-page placement; ensure headers/footers include legend across all pages in final.

Do not include pricing information in Volume I

Section L and Volume instructions; also warns price info only in price volume

Draft states Volume I is free of pricing; price narrative includes credit-hour rate approach (but no numbers)

Partial

Even narrative about price mechanics may be allowed if in price volume only. Move all pricing narrative to the price volume file; keep Volume I strictly non-price.

No alternate proposals; no exceptions to material terms (exceptions = deficiency/ineligible)

Section L: alternate proposals not authorized; exceptions render ineligible

Draft generally states compliance; does not explicitly affirm "no exceptions" / unconditional assent

Partial

Add explicit statement of unconditional assent and no exceptions/tailoring to solicitation terms and attachments.

Certify included in DAPIP and maintain regional accreditation

Section L(a): certify DAPIP inclusion and maintain regional accreditation

Explicit certification; commitment to maintain and notify CO of changes

Covered

Strong alignment; includes notification commitment.

Complete Attachment I USNCC CIAS Checklist of the Database of Accreditation for Postsecondary Institutions

Section L(a): complete Attachment I checklist

States it will provide completed checklist and documentation

Partial

Checklist itself not included in the draft text; ensure completed Attachment I is included in submission package.

Provide sufficient detail; avoid paraphrasing/PWS-only statements

Section L note: general assurances inadequate

Draft provides process-level detail (program office, workflows, early alerts, governance)

Covered

Maintain specificity and make sure each claim ties to concrete actions/deliverables.

Forward-looking approach to accomplish solicitation + PWS requirements

Section L(b): detailed, forward-looking performance approach

Detailed operating model; program office governance; lifecycle workflow; QA

Covered

None

Discuss non-academic functional/ancillary services: admissions/enrollment, online delivery, student support

Section L(b): must include admissions/enrollment, online course delivery, student support

Separate sections for admissions/enrollment, online delivery, support/retention

Covered

None

Address alignment to USNCC learning outcomes and needs of the services

Section L(b): align with USNCC learning outcomes and service needs

Mentions mapping outcomes and accommodating maritime operational realities

Partial

Add explicit crosswalk example: USNCC learning outcomes → program/course outcomes → assessment/metrics reporting.

Transition plan: launch new programs + scenarios (institution closure/program closure teach-out; USNCC discontinues; student leaves USNCC; student leaves Service; contract termination/continuity)

Section L(b): transition plan must address these scenarios

Comprehensively addresses each scenario, including continuity and data transfer

Covered

None

Risk identification + mitigation; state if mitigations have been used successfully

Section L(b): describe risks, mitigations, and whether used successfully

Risk section lists categories and mitigations; states based on proven practices

Covered

Consider adding a short evidence statement per mitigation (e.g., prior program scale, KPI improvements) without drifting into past performance narrative.

Phase I Acceptable required to proceed

Section L/M: Phase I acceptability gate

Accreditation/DAPIP certification included; checklist not shown

Medium

Performance Approach and Academic Capabilities must be at least Acceptable or proposal ineligible; Past Performance must be ≥ Satisfactory Confidence

Section M: rating thresholds

Performance Approach narrative strong; Academic Capabilities missing required one-page forms; Past Performance references/forms not included

High

No pricing info in Volume I; price volume strictly price info

Section L: separation; strict limits

Draft includes a “Price Proposal Narrative” section within same text; no numbers but could be viewed as price-volume material in non-price volume

Medium

CMMC UID(s) + current CMMC status/affirmation required for eligibility (if FCI/CUI systems used)

DFARS 252.204-7025(b)(2), (d)

No UIDs/status/affirmation included

High

Past Performance must be provided per form and meet specificity or may not be evaluated

Section L(d)

Only a plan/commitment; no completed forms/references in the draft text

High

Separate price volume containing: signed SF1449, pricing pages, Attachment I pricing spreadsheet (Excel), unlocked/searchable

Section L Volume II / Volume III price instructions: include signed SF1449, pricing pages, Attachment I spreadsheet in Excel

Draft commits to submit signed SF1449, pricing pages, Attachment I spreadsheet in Excel

Partial

Actual signed SF1449 and completed pricing sheets not included here; must be produced for compliance.

Credit hour rates rounded to 2 decimals; no formulas; credit hour rate prevails

Section L price notes: rounding and precedence

Draft matches requirements

Covered

None

Price held firm for 180 days

Section L/M: validity 180 days

Draft commits 180 days

Covered

None

Price analysis only (no realism); may request support like invoices/sales history/catalog pages; failure may disqualify

Section M: may request support; failure may disqualify

Draft states readiness to provide sales data/catalog etc.

Covered

Ensure you have redaction and substantiation strategy ready.

Identify and price all subcontracts; provide list of all subs, contract type, value, cognizant security office

Section L price note (f): list subs + details + security office

Draft mentions pricing incidental subcontracted elements generally; no list/details

Gap

If any subcontractors exist (even incidental), omission creates compliance risk.

Economic price adjustment clause will be included; acknowledge/reflect approach

Section L price: EPA clause included

Draft does not acknowledge EPA clause

Gap

Add acknowledgement and explain how tuition/fee changes will be handled within EPA terms (without proposing exceptions).

Provide CMMC UID(s) for each contractor information system processing/storing/transmitting FCI/CUI; update list as new UIDs generated

DFARS 252.204-7025(d) and 252.204-7021(e): proposal must include CMMC UID(s)

Draft mentions CUI/FCI in acronyms and discusses access controls but does not provide CMMC UIDs or CMMC status

Gap

High eligibility risk: solicitation states offeror is not eligible without current CMMC status + UID(s) + affirmation in SPRS.

Have current CMMC status at required level for relevant systems; current affirmation of continuous compliance in SPRS

DFARS 252.204-7025(b)(2): ineligible without current status and affirmation

No explicit statement of CMMC status/level, SPRS affirmation, or system scoping

Gap

High risk of ineligibility at award.

Flow down CMMC requirements to subcontractors handling FCI/CUI

DFARS 252.204-7021(d)(1)(ii) and (f): flowdown required

Draft does not address CMMC flowdown

Gap

Add subcontractor handling model and flowdown commitment.

252.204-7012 Safeguarding Covered Defense Information & cyber incident reporting (contract clause) – address approach (where proposal requests/needs)

Section I includes 252.204-7012 by reference

Draft speaks generally about access controls and audits; no incident reporting, media protection, encryption, SSP/POA&M posture, etc.

Partial

Not always required in Volume I, but given CUI/FCI and CMMC, add a concise compliance statement and operational approach.

Covered telecom representations (FAR 52.204-24/26; DFARS 252.204-7016/7017) and FASCSA (52.204-29)

Section K includes representations/provisions; may be completed in SAM or in proposal

Draft says reps/certs current in SAM or will provide in price volume; does not state specific answers

Partial

Ensure the price volume clearly indicates SAM completion OR includes completed provisions with explicit selections/disclosures as applicable.

No classified data in proposal

Section L: do not include classified data

Draft explicitly confirms no classified information included

Covered

None

Certificate if non-employee participated in proposal writing; include in price volume, signed by officer, with required details

Section L: certificate required if non-employee participated

Draft includes non-employee participation disclosure and commits to provide certificate if applicable

Covered

If truly none participated, consider adding the signed certificate anyway (as an affirmative statement) if permitted, or ensure your statement is in correct volume per instructions.

Unconditional assent; do not alter solicitation; exceptions = deficiency

Section L: unconditional assent; do not alter; exceptions disqualify

Draft says submitted in strict accordance; does not explicitly state unconditional assent/no exceptions

Partial

Add explicit sentence: “We take no exceptions to the terms, conditions, clauses, PWS, and attachments.”

Provide up to three most relevant references within past five years OR affirm no relevant past performance

Section L(d): up to three; or affirm none

Draft states it will provide up to three and describes what will be included

Partial

Actual references not provided in the draft; must include completed forms and narratives.

Use Past Performance Information Form for each reference; continuation sheets count to page limits

Section L(d): form required; continuation allowed

Draft mentions using required form

Partial

Include the actual completed forms and ensure within page limits.

If references are TO/DOs under IDIQ/BPA/FSS: include vehicle # and task order #; do not cite the IDIQ/BPA/FSS alone

Section L(d): specific instruction

Draft commits to include order numbers/timeframes/dollar values

Covered

Ensure compliance per reference.

Combination reference rules (≤2 orders combined; only one combination allowed; each within 5 years; must detail experience/PoP/$ each)

Section L(d): combination constraints

Draft acknowledges combination concept generally

Partial

Add an explicit statement that you will comply with the one-combination limit and the ≤2-orders-per-combination constraint if used.

Cite PWS task sections/subsections to which past performance is relevant

Section L(d): cite PWS sections

Draft says it will explicitly connect to principal elements; does not mention PWS section citations

Gap

Add PWS cross-reference citations per reference to avoid “may not be evaluated” outcome.

Subcontractor/partner past performance weighted proportional; must detail what they will do under this solicitation

Section L(d): proportional weighting and required description

Draft describes proportional weighting and intent to detail responsibilities

Covered

If proposing any subs, ensure roles are described in Volume I and priced/identified in price volume per Section L price notes.

Differentiate subcontractor effort vs overall contract when reference is as subcontractor

Section L(d): must differentiate $ and work

Draft explicitly commits to differentiate

Covered

None

Affiliate past performance only with meaningful involvement; must describe relationship and involvement (no 'reach-back only')

Section L(d): meaningful involvement rules

Draft does not address affiliate past performance

Not Applicable

Only applicable if you plan to claim affiliate past performance.

R-01

Proposal deemed ineligible due to missing CMMC UID(s)/status affirmation

No CMMC UID(s), CMMC level/status, SPRS affirmation evidence, or system boundary description provided

Medium

High

High

Add CMMC UID(s) for each in-scope system; state CMMC status level is current; affirm annual continuous compliance affirmation in SPRS; describe which systems handle FCI/CUI and ensure subcontractor flowdown.

R-02

Academic programs not considered for award; reduced scope in base contract

Missing required one-page-per-field degree information forms tied to classification attachment

High

High

Critical

Include completed degree information forms for each academic field/program; add an index table mapping fields to form pages.

R-03

Past Performance factor evaluated as weak/nonresponsive; potential < Satisfactory Confidence

No completed Past Performance Information Forms; missing PWS task cross-references; no actual references

High

High

Critical

Provide up to three references with completed forms; include relevance narratives with PWS section/subsection citations; ensure any order-combination rules are met and explicitly stated.

R-04

Non-price volume flagged for containing price volume content

Embedded pricing compliance summary appears in Volume I text (even without numbers)

Medium

Medium

Medium

Move all pricing narrative and any price-related compliance statements into the separate price volume; keep Volume I purely non-price.

R-05

Submission noncompliance (wrong email, missing exact deadline/time zone acknowledgement)

Draft uses placeholders and does not restate exact submission details

Low

High

Medium

Add a submission compliance block listing the exact email address, deadline, time zone, and a statement that submission is via attachments only.

R-06

Subcontract pricing/listing compliance failure (if any subcontractors used)

No subcontractor list, contract types, values, or cognizant security office details

Medium

Medium

Medium

If any subcontractors exist, include the required subcontractor list and details in price volume and ensure consistency with Volume I technical approach.

Submit to specified POC email; by due date/time; late proposals not evaluated

Section L: email to john.d.favata.civ@us.navy.mil; due 12:00 PM Philadelphia Time 21-April-2026

Draft includes generic placeholders; does not restate exact email and due date/time

Gap

Administrative noncompliance risk (submission instructions are strict). Add exact submission address, deadline, and time zone acknowledgement.

Attachments only; no hyperlinks/portals/physical media

Section L: other delivery methods not accepted

Draft does not explicitly confirm "no hyperlinks/attachments only"

Partial

Add explicit compliance statement to avoid ambiguity.

File formats: Adobe Acrobat + MS Office (Excel) unlocked and searchable; virus-free

Section L: unlocked/searchable; virus free

Draft confirms virus-free, unlocked, searchable; Excel for pricing spreadsheet noted

Covered

Ensure final PDFs are text-searchable (not image-only) and not password-protected.

Email size limit 10MB; multiple emails labeled with solicitation #, volume, sequence

Section L: 10MB max; labeling guidance

Draft commits to <10MB and labeling

Covered

None

Offeror encouraged to confirm receipt prior to deadline

Section L: confirm receipt prior to date/time

Draft does not mention confirmation/receipt-check step

Gap

Add operational step (e.g., request read receipt / follow-up) to reduce late/non-receipt risk.

Questions due consolidated list by 07-April-2026 12:00 PM Philadelphia Time

Section L: consolidated questions submission deadline

Draft does not address

Not Applicable

Not required in proposal unless you intend to ask questions; ignore unless submitting Q&A.

Address academic capabilities for fields identified in Attachment (Academic Program Classification)

Section L(c): address fields in Attachment (notes show Attachment II/III naming inconsistencies in solicitation text, but intent is the classification attachment)

Narrative states intent to support fields and to complete forms

Partial

Missing the actual field-by-field submissions; risk that fields are not considered for award.

Complete degree information form; provide all requested information; each program submission ≤ 1 page

Section L(c): degree info form required; 1 page each

States commitment to submit one-page forms; does not include the forms/data

Gap

High risk: without the forms, academic programs may not be evaluated or awarded into base contract scope.

Breadth evaluated in aggregate to determine technical superiority

Section L(c): aggregate evaluation; breadth matters

Draft acknowledges breadth strategy

Covered

Add a concise table listing fields/programs you are proposing under the MAC (even if details are in the one-page forms).

Add an explicit “No Exceptions / Unconditional Assent” statement covering the solicitation, PWS, attachments, FAR/DFARS clauses, and amendments

input_proposal.docx

Section L states affirmative exceptions are deficiencies and ineligible; solicitation warns not to alter terms

Reduces ambiguity and deficiency risk

Separate artifacts cleanly into two files/volumes; remove the price narrative section from the non-price volume and place it into the price volume document

input_proposal.docx submission package

Section L requires separate volumes and prohibits price info outside price volume

Avoids nonresponsive finding based on volume contamination

Insert a submission compliance block (cover page or cover letter) that repeats the exact submission email, due date/time (Philadelphia time), attachment-only rule, and confirmation-of-receipt intent

input_proposal.docx

Section L submission instructions are strict and late/nonconforming proposals not evaluated

Strengthens administrative compliance posture

Provide the completed Attachment I USNCC CIAS accreditation checklist and any supporting documentation (as required by the attachment)

input_proposal.docx package

Phase I requires completion of Attachment I checklist

Improves likelihood of Phase I Acceptable rating

Deliver Academic Capabilities as required: completed degree information form for each academic field/program, each limited to one page; add an index table of all proposed fields/programs

input_proposal.docx (Academic Capabilities section + attachments)

Section L(c) warns missing specificity may result in program not being considered for award

Maximizes programs included in resultant IDIQ scope; improves technical superiority

Provide Past Performance exactly as required: up to three references with completed Past Performance Information Forms, relevance narratives, PWS section/subsection citations, and clear order/vehicle identifiers

input_proposal.docx (Past Performance section + forms)

Section L(d) states references lacking detail may not be evaluated; Section M sets awardability threshold (≥ Satisfactory Confidence)

Improves confidence rating and award eligibility

Add CMMC compliance package content: CMMC level/status statement, CMMC UID(s) for each system processing/storing/transmitting FCI/CUI, SPRS affirmation statement, and subcontractor CMMC flowdown commitment

input_proposal.docx and/or price volume as instructed

DFARS 252.204-7025 requires UIDs in the proposal and makes eligibility contingent on current status/affirmation

Addresses a primary award eligibility gate; reduces disqualification risk

If any subcontractors are used (even incidental): include the required subcontractor list with contract type, value, and cognizant security office details; ensure they are priced in the price volume

Price volume + cross-consistency with Volume I

Section L price note (f) requires identification/pricing and security office details

Prevents compliance findings and strengthens evaluability

Strengthen USNCC learning outcomes alignment by adding a concise outcomes crosswalk example and associated KPIs/data reporting approach

input_proposal.docx (Performance Approach)

Section L(b) requires discussion of alignment to USNCC learning outcomes; evaluation discourages generic statements

Improves Performance Approach rating defensibility

Acknowledge the economic price adjustment clause and describe how tuition/fee changes will be administered under the clause (without taking exceptions)

Price volume narrative

Price instructions state an EPA clause will be included

Shows awareness of contractual mechanism; reduces negotiation friction