USCG Construction IFB Bid Compliance Gap Analysis (SF 1442)

Likely domain

Federal procurement (USCG) construction sealed bidding

Federal procurement (USCG) construction sealed bidding

Primary purpose

Bidder’s offer/response to IFB; includes narrative commitments and placeholders for SF 1442 blocks and pricing

Binding IFB solicitation; contains SF 1442, Sections A–M, clauses/provisions, admin instructions

Acquisition type

Sealed Bid / Firm-Fixed-Price (asserted)

Sealed Bid IFB / Firm-Fixed-Price (FAR 52.216-1)

Project

Major Repairs Boiler Plant (PSN 21590583)

Major Repairs Boiler Plant (PSN 21590583)

Location

U.S. Coast Guard Academy, New London, CT

U.S. Coast Guard Academy, New London, CT

Magnitude noted

Not stated

$1M–$5M estimate (Section A)

Set-aside

States 100% Total Small Business set-aside; claims small business

100% Total Small Business set-aside; NAICS 236220, size standard $45M

Key compliance nature

Bid responsiveness (forms/acknowledgments/bid bond) + post-award admin (bonds, insurance, IPP)

Bid responsiveness rules + post-award contract clauses

Period of performance window 6/1/2026 to 6/1/2027

SF1442 Item 10; Section B; Section F

Draft explicitly acknowledges 06/01/2026–06/01/2027

Covered

—

Commence within 10 calendar days after Notice to Proceed

SF 1442 Item 11; Section F.1

Draft: 'commence performance within ten calendar days after receipt of the Notice to Proceed'

Covered

—

Complete within 365 calendar days after NTP; includes final cleanup

Section F.1

Draft acknowledges 365 days after NTP; mentions final cleanup in approach/pricing

Covered

—

Blackout periods (no work)

Section F.1: May 17–20 2026; June 30 2026; Fall 2026 Parents Weekend TBD; Fall 2026 Homecoming TBD

Draft acknowledges blackout periods (Commencement Week, R-Day, event weekends) but does not list exact dates/ranges

Partially Covered

For execution, schedule should incorporate exact stated blackout dates and handle TBD dates via coordination; consider explicitly listing May 17–20 and June 30 to show precise alignment.

Schedule submission within 5 days after work commences; form progress chart; update continually; supplemental recovery schedules; Govt may withhold payments/terminate

FAR 52.236-15 (Deviation)

Draft commits to submit schedule 'within the timeframe directed' and references FAR 52.236-15 and withholding/termination concepts

Partially Covered

Draft does not explicitly commit to the 'within five days after work commences' requirement nor to the required 'progress chart' format. Risk of later noncompliance dispute.

Recovery at no additional cost if behind schedule (shifts/overtime/plant)

FAR 52.236-15(c)

Draft commits ability to add shifts/overtime without additional cost when recovery required due to contractor performance

Covered

—

Time extensions depend on extent of change delays; element-specific extensions possible

FAR 52.211-13

Not mentioned

Gap

Not required in bid narrative, but acknowledging change-driven schedule analysis approach can reduce later disputes.

Suspension of work clause exists

FAR 52.242-14

Not mentioned

Gap

Informational; not required as bidder-provided data.

Accident prevention; OSHA; barricades/signs; corrective action; stop-work without adjustment; flowdown to subs

FAR 52.236-13

Draft commits to FAR 52.236-13, OSHA compliance, site controls; does not explicitly mention stop-work no equitable adjustment; states will flowdown safety and labor standards generally

Partially Covered

Consider explicitly acknowledging stop-work/corrective action terms and subcontract flowdown requirement for this clause.

Accident & fire reporting

HSAR 3052.223-90

Draft explicitly commits to report accidents/fires per HSAR 3052.223-90

Covered

—

Hazardous substance removal/disposal: required licenses/permits; evidence prior to commencing; timelines per specs; no activity until permits obtained

HSAR 3052.223-70 (H.3)

Draft commits to obtain/maintain required licenses/permits and not commence until approvals in place

Covered

—

Site investigation; failure to inspect not grounds for claim

FAR 52.236-3; FAR 52.237-1 site visit

Draft mentions it reviewed site conditions generally and will document discrepancies; does not explicitly acknowledge inspection/no-claim consequence

Gap

Including explicit statement can reduce later disputes and aligns with solicitation caution.

Protection of existing structures/utilities/improvements; repair damage

FAR 52.236-9

Draft generally mentions protection of existing utilities/improvements

Partially Covered

Does not explicitly commit to prompt repair at contractor expense or CO remedy to charge contractor.

Cleaning up / housekeeping

FAR 52.236-12; also referenced in Draft

Draft commits to debris removal/clean worksite and final cleanup

Covered

—

Bid responsiveness & submission

6

6

5

Gaps mostly due to unfilled SF1442/pricing fields that would be fatal if not completed in actual bid package.

Performance & schedule

4

2

3

Most schedule obligations acknowledged; missing explicit 5-day schedule submission and progress chart format.

Bonds/insurance/admin submittals

3

2

3

Insurance limits and shop drawings/keeping specs on site not explicitly acknowledged.

Payments/IPP/admin contacts

3

1

1

Minor gap on invoice discount offering statement.

Subcontracting & reporting

2

4

2

Key gap: SF1413 14-day requirement; reporting clauses acknowledgments.

Safety/hazmat/site

3

2

2

Site visit/no-claim and protection/repair specifics missing.

Security/access/IT supply chain

0

0

7

Major gap area: HSAR access/CUI training, FAR 52.240-93 safeguarding, FAR 52.240-90/91 representations, E-Verify, whistleblower notice.

Overall (this extract)

24

17

23

High volume of clause-driven items in IFB; bidder narrative covers many construction-execution topics but misses multiple explicit representations/compliance acknowledgments.

Sign and return ONE original of the entire solicitation form

IMPORTANT NOTICE TO BIDDER #1(b): 'Sign and return ONE original of the entire solicitation form'

States: 'submitted as one original sealed bid package' and 'contains a fully completed SF 1442 offer section'

Partially Covered

Narrative claims completion, but Draft Document text itself shows blanks for offeror identity, acceptance days, amendment list, signature. If submitted as-is, risk of nonresponsive bid.

Offer section on SF 1442 must be fully completed

SF 1442 page 2 note: must be fully completed; Item 17 acceptance days; Items 14–16; Items 19–20 signatures/dates

Contains placeholders for Offeror, address, telephone/fax, TIN, UEI, CAGE; acceptance period blank; signature blocks blank

Gap

If these fields remain blank in the actual submission, bid is nonresponsive.

Bid due date/time and place; sealed envelope marking

SF 1442 Item 13A: bids due 3/12/2026 2:00 PM local time; mark envelope with name/address, solicitation number, due date/time; address to USCG CEU Providence, Warwick RI

States delivery will be made to address specified; states sealed package marked and addressed per solicitation; does not restate the address/time/date

Partially Covered

No explicit reproduction of exact address/time/date in Draft Document; not required if followed, but increases execution risk. Consider mirroring the exact address and deadline to reduce internal error.

No email/telegraphic/telephonic/fax bids

IMPORTANT NOTICE TO BIDDER #5; plus statement no email etc.

Explicitly states email/telegraphic/telephonic/facsimile bids will not be accepted and bidder ensured delivery accordingly

Covered

—

Acknowledge all amendments

IMPORTANT NOTICE #2(a); SF 1442 Item 19; FAR 52.214-3 acknowledgment by time/place for bids

Provides amendment acknowledgment section with blanks and explains nonresponsiveness risk if not acknowledged

Partially Covered

Must actually list amendment numbers/dates or 'None'. As provided, still blank.

Bid acceptance period >= 60 days

IMPORTANT NOTICE #3; SF 1442 Item 13D and Item 17

States acceptance period blank but 'not less than sixty calendar days' and warns bids <60 will be rejected

Partially Covered

Must insert a number (or leave blank to accept minimum) on actual SF1442. Draft has blank line; acceptable if intentionally left blank, but ensure consistency with actual SF 1442 submission.

Bid guarantee 20% (SF 24) required and included

IMPORTANT NOTICE #2(d); FAR 52.228-1; SF 24 in Section J

States bidder will furnish SF24 bid bond 20% and that it accompanies bid submission

Covered

Ensure SF24 executed properly and penal sum equals 20% of total bid.

Include all applicable taxes; no tax-exempt number

IMPORTANT NOTICE #8; reiterated in SF1442/Section B

States all applicable taxes included; no tax-exempt number expected

Covered

—

Pricing schedule completed (Section B) and total lump sum (Items 0001-0005)

SF 1442 Item 17; Section B pricing schedule

Provides line items 0001–0005 with blanks; total lump sum blank; states includes all work

Gap

Pricing must be filled in and consistent across SF1442 total and Section B schedule to be responsive.

Public opening at due time

SF1442 13A mentions public opening

Not mentioned

Gap

Not required as bidder action, but including is optional; no compliance impact.

Questions due date/time and method

Cover sheet: questions due 2 March 2026 4:00PM; IMPORTANT NOTICE #4 also says not later than 9 March 2026 by 4:00PM (inconsistency); Section F site visit says questions by March 2, 2026 4:00PM

Draft references questions due and provides general understanding of communications but does not address inconsistency

Gap

Internal inconsistency in solicitation; bidder may request clarification pre-bid. Not a bid responsiveness requirement but could affect interpretation.

Site visit urged/expected; organized visit date/time; no questions during visit

CAUTION TO BIDDERS; Section F.2: site visit Feb 24 2026 10:30am; no questions allowed

Draft does not state attendance or acknowledgment of site visit details

Gap

Not attending typically not disqualifying, but increases risk of differing site condition misunderstandings and weaker position for claims.

Funds not currently available; Government may cancel

IMPORTANT NOTICE #10

Draft explicitly acknowledges funds not currently available and right to cancel

Covered

—

Performance and payment bonds 100% within 10 calendar days after award (Item 12B TEN)

SF1442 12A/12B; FAR 52.228-15

Draft commits to 100% bonds within ten calendar days after award

Covered

—

Bid bond 20% SF24

FAR 52.228-1; IMPORTANT NOTICE #2(d)

Draft states SF24 20% accompanies bid

Covered

—

Miller Act payment bond notice flowdown (HSAR 3052.228-90)

HSAR 3052.228-90

Draft states will ensure first-tier subs flow down notice clause and support Govt administration; but does not provide surety contact info (which is required in the notice clause to be inserted by first-tier subs)

Partially Covered

Post-award: prime must supply surety info to subs; draft cannot fill until surety chosen. Consider stating bidder will provide surety name/address/phone for inclusion in HSAR notice upon bond issuance.

Insurance certificate within 10 days after award; 30-day cancellation notice; minimum coverages ($500k CGL; Auto $200k/$500k/$20k; WC per law)

Section H.1; HSAR 3052.228-70; FAR 52.228-5

Draft commits to FAR 52.228-5 and HSAR 3052.228-70; certificate within 10 days; 30-day cancellation notice; mentions CGL/auto/WC but not the dollar limits

Partially Covered

Draft should explicitly acknowledge meeting/exceeding the stated minimum limits from Section H.1 to reduce compliance ambiguity.

Preconstruction conference attendance if required

H.56

Not mentioned

Gap

Not a bid responsiveness item; but commitment can reduce later friction.

Keep drawings/specs on site; shop drawing approval/variation process

FAR 52.236-21

Draft mentions submittals generally and discrepancy reporting; does not explicitly address shop drawings approval/variations or keeping copies on site

Gap

Likely handled in submittal plan; including explicit acknowledgment helps align with clause expectations.

Permits and responsibilities (licenses/permits; comply with laws/codes)

FAR 52.236-7

Draft states full responsibility for permits and code compliance; mentions licenses/permits for hazardous

Covered

—

Submit payment requests via IPP; comply FAR 32.905(b); alternate method only if CO authorizes in writing

Section G.1

Draft commits to IPP and FAR 32.905(b) compliance; mentions supporting docs

Covered

—

Include discount offerings and small business status if available on invoices

Section G.1(a)

Draft does not mention discount offerings statement on invoices

Gap

Not typically bid-responsive, but is an explicit invoicing instruction.

Receiving Official / Invoice Approver / COR emails

G.1(f) lists Simon W. Leung; Ethan A. Geurtsen

Draft states it will coordinate with COR and Receiving Official as identified in Section G; does not name them

Partially Covered

Not required, but including the named officials/emails can demonstrate precise alignment and reduce misrouting risk.

Prompt Payment for Construction: 30 days (in lieu of 14)

FAR 52.232-27

Draft acknowledges prompt payment '30 days' and will manage billing to support timely payment

Covered

—

Payment by EFT tied to SAM; maintain SAM active through final payment

FAR 52.232-33; FAR 52.204-13 maintenance

Draft states SAM will remain active through final payment

Covered

—

Contractor employee access; background investigations/credentialing; CUI handling limits; CUI training within 60 days and refresher every 2 years; flowdown

HSAR 3052.204-71

Draft states it will comply with access requirements including forms, background checks/credentialing; does not mention CUI training timelines or CUI use/disclosure limits

Gap

If work involves CUI (clause says may), contractor needs explicit process acknowledgment. Risk: compliance findings or access delays.

Basic safeguarding of covered contractor information systems (FCI) controls; flowdown

FAR 52.240-93

Not mentioned

Gap

Even for construction, FCI may exist (drawings, security info). Draft should acknowledge minimum safeguarding controls and subcontract flowdown where FCI transits.

Security prohibitions & exclusions reps/certs (covered telecom/video surveillance, FASCSA orders, Sudan/Iran; disclosure duties)

FAR 52.240-90 provision and FAR 52.240-91 clause

Not mentioned

Gap

These are offeror representations by submission; omission in narrative may be acceptable if completed in SAM/required forms, but Draft Document provides no explicit representation/disclosure mechanism.

E-Verify employment eligibility verification

FAR 52.222-54

Not mentioned

Gap

Clause requires enrollment/verification steps; not addressed in Draft.

Whistleblower rights notice to employees; flowdown to subcontracts

FAR 52.203-17

Not mentioned

Gap

Clause requires written notice in predominant workforce language; Draft omits.

VETS-4212 reporting and equal opportunity clauses (veterans/disabilities) flowdowns

FAR 52.222-35/-36/-37

Not mentioned

Gap

Not typically included in bid narrative, but still a compliance requirement; Draft doesn’t acknowledge.

100% Total Small Business set-aside; non-small bids rejected

IMPORTANT NOTICE #7; FAR 52.219-6

Draft acknowledges set-aside and represents it is small business

Covered

—

Limitations on subcontracting (general construction: max 85% to non-similarly situated; materials excluded)

FAR 52.219-14

Draft states will comply with 85% rule excluding materials and references similarly situated entities concept

Covered

—

Submit SF 1413 for every subcontractor (including lower tiers) before subcontractor begins work

Section H.4

Draft commits to executing and submitting SF 1413 for each subcontractor prior to mobilization; also mentions lower tiers in general

Partially Covered

H.4 specifically requires SF1413 for every subcontractor (including second or lower tier) performing at site before they begin work. Draft mentions 'for each subcontractor' and 'prior to mobilization' but does not explicitly confirm second/lower tier coverage in that sentence.

FAR 52.222-11 requires SF1413 delivery within 14 days after award for each subcontract; and within 14 days after subsequent sub awards

FAR 52.222-11(d)

Draft says SF1413 prior to mobilization (and elsewhere 'prior to mobilization at the construction site'); not the 14-day-after-award submission requirement

Gap

Potential post-award compliance risk: clause requires submittal timelines independent of mobilization.

Maximize small business participation (FAR 52.219-8) and timely payment to small business subs

FAR 52.219-8; FAR 52.232-40 accelerated payments to small business subs is in clauses list

Draft commits to maximizing practicable small business participation and timely payments; does not mention accelerated payments clause

Partially Covered

Accelerated payments requirement is clause-based; not necessary in bid narrative, but acknowledging process supports alignment.

Report executive compensation and first-tier subcontract awards in SAM if thresholds triggered

FAR 52.204-10

Draft says will comply with reporting if triggered and coordinate through SAM

Partially Covered

Should explicitly cite FAR 52.204-10 reporting and that subs will be notified information will be public.

Annual service contract reporting requirement (52.204-19 in this IFB set includes 52.204-14 service contract reporting)

FAR 52.204-14

Not mentioned

Gap

If applicable to this construction contract as included, contractor must report annually by Oct 31. Draft does not acknowledge.

Nonresponsive bid due to incomplete SF 1442 blocks (offeror ID/signature/acceptance days)

SF 1442 must be fully completed; IMPORTANT NOTICE #1(b)

Draft shows blanks for offeror identity fields, acceptance period line, amendment list, and signature/date

High (if not completed)

Critical (rejection)

Ensure final submitted package contains fully executed SF1442 with all blocks completed, dated, and signed by authorized person; cross-check against Section K and SAM reps as applicable.

Nonresponsive bid due to missing prices

Section B pricing schedule required; SF 1442 total lump sum

All line items and totals are blank placeholders

High (if not completed)

Critical (rejection)

Populate all line items 0001–0005 and total; verify arithmetic; ensure consistency between SF1442 Item 17 total and Section B schedule.

Nonresponsive bid due to amendment non-acknowledgment

SF1442 Item 19; FAR 52.214-3

Amendment section present but blank; narrative warns of risk

Medium

High

List all amendment numbers/dates or state 'None' on SF1442; include signed amendment pages if required.

Bid bond submission/penal sum errors

FAR 52.228-1; IMPORTANT NOTICE #2(d)

Draft claims SF24 accompanies bid but no bond details

Medium

High

Include executed SF24 with correct surety, signatures, and penal sum = 20% of total bid; validate power of attorney.

Delivery/address/time errors causing late bid

SF1442 13A; FAR 52.214-7

Draft does not restate exact address/time/date; relies on solicitation

Low-Medium

Critical (late bids not considered)

Add explicit delivery address, bid due date/time, and envelope marking checklist in bid transmittal cover letter.

High

Complete all SF 1442 offer fields in the final submitted package: Offeror name/address/phone; TIN/UEI/CAGE; remittance address; acceptance period; amendment acknowledgment; authorized signature and offer date.

SF 1442 Items 14–20; IMPORTANT NOTICE #1

Directly prevents nonresponsive bid rejection in sealed bidding.

High

Fill Section B pricing schedule (0001–0005) and ensure the SF 1442 total lump sum matches exactly; include internal arithmetic check statement.

Section B; SF 1442 Item 17; IMPORTANT NOTICE #2(b)

Prevents rejection and mitigates unbalanced/miscalculated bid risk.

High

Add explicit written representations/acknowledgments in the offer package (or confirm completion location) for: FAR 52.240-90/91 security prohibitions; FAR 52.240-93 safeguarding; HSAR 3052.204-71 CUI access/training; FAR 52.222-54 E-Verify; FAR 52.203-17 whistleblower notice flowdown.

Section I clauses/provisions

Closes major compliance blind spots that can affect eligibility, responsibility, and post-award performance (especially DHS supply chain and information protection).

High

Align schedule commitments to FAR 52.236-15 specifics: commit to providing the initial practicable progress chart schedule within the clause-specified period (5 days after work commences unless otherwise directed), continuous updates, and supplemental recovery schedules when behind.

Section F.4

Reduces risk of payment withholds/termination for failure to prosecute work diligently.

Medium

Explicitly acknowledge insurance minimum limits from Section H.1 (CGL $500k; Auto $200k/$500k/$20k; WC per law) and confirm certificate will evidence these limits and 30-day cancellation notice.

Section H.1/H.2

Avoids ambiguity and speeds award-to-NTP administrative review.

Medium

Update subcontract/SF1413 language to meet both requirements: (1) Section H.4 (before subcontractor begins work, including lower tiers) and (2) FAR 52.222-11(d) (deliver SF1413 within 14 days after award and within 14 days after subsequent sub awards).

H.4; FAR 52.222-11(d)

Prevents post-award noncompliance findings and site-access delays for subs.

Medium

Add an explicit statement acknowledging the site visit expectation and the no-claim consequence for failure to inspect, consistent with FAR 52.236-3 and FAR 52.237-1 (even if you did not attend).

Section F.2; FAR 52.236-3; FAR 52.237-1

Strengthens the Government’s confidence in bidder’s understanding of site conditions; reduces disputes.

Medium

Add explicit commitment to shop drawing/submittal governance per FAR 52.236-21 (contractor review/approval stamp; variation letters; no work before approval; keep drawings/specs on site).

FAR 52.236-21

Improves alignment with submittal/QA administration expectations.

Low

Add invoice content detail: state whether prompt payment discounts will be offered (or state none) and include small business status on payment requests, consistent with Section G.1(a).

Section G.1(a)

Avoids invoice rejection/processing delays.

Low

Mirror key bid logistics on the cover page (bid due date/time, physical address for delivery, and marking instructions) to reduce internal delivery errors.

SF 1442 Item 8 & 13A; FAR 52.214-5

Operational risk reduction (late bid).