USCG Lodging RFQ Proposal Gap Analysis: SOW and Clause Compliance

1.1 Background

Lodging to house rotating crewmembers/support; award basis references past performance/best value under FAR 13.106-2

Addresses mission readiness; discusses past performance generally but provides no specific past performance references in text (Sec. 11.0)

Partially Covered

If the RFQ requires past performance submissions/CPARS references, add explicit past performance examples or confirm included in Reference Information Sheet.

1.2 Scope

Continuously provide 6 rooms; transfer days ready same day; individual bedrooms/bathrooms

Explicitly commits (Sec. 4.0)

Covered

None.

2.1

Rooms grouped together; away from noise/traffic

Explicitly commits (Sec. 4.0)

Covered

None.

2.2

MUST be within 40 min response; calculated via Google Maps

Commits; references method (Sec. 4.0)

Partially Covered

Provide address + Google Maps time/distance evidence and state it will remain within 40 minutes throughout POP (consider traffic/time-of-day assumptions).

2.3

Provide cable TV and internet

Commits; includes outage escalation (Sec. 4.0)

Covered

None.

2.4

Furnished (beds/couch/chairs/dining table/dressers/nightstands etc.); utilities included; refrigerator + microwave

Commits (Sec. 2.0; 4.0)

Covered

None.

2.5

Linens weekly minimum; towels daily/as needed

Commits; adds logs (Sec. 5.0)

Covered

None.

2.6

Minimum 2 parking spots

Commits (Sec. 6.0)

Covered

None.

2.7

Structurally sound; level floors; staircases stable; walls/ceilings free of holes/large cracks

Commits (Sec. 6.0)

Covered

None.

2.8

Free of mold, stains, objectionable odors, infestations

Commits (Sec. 6.0; 5.0)

Covered

None.

2.9

Walls/ceilings/furnishings free of water/dirt/stains/damage/infestations

Commits (Sec. 6.0)

Covered

None.

2.10

Appliances incl. heating/cooling clean and working, free of defects

Commits; preventive/corrective maintenance (Sec. 4.0; 5.0)

Covered

None.

2.11

Exterior walls clean; free of dirt and bird/animal/insect excrement

Commits (Sec. 6.0)

Covered

None.

2.12

Units in immediate vicinity of each other due to duty crew coordination/response

States rooms will be grouped together as much as possible (Sec. 4.0)

Partially Covered

Add explicit statement: all six rooms will be in the same facility and same immediate area (same floor/wing) unless Government approves otherwise.

2.13

Safe, quiet, peaceful neighborhood free of frequent disputes/illegal activity

Commits; includes mitigation/relocation (Sec. 6.0)

Covered

None.

7.0–7.2

COR acceptance by email; rejection reasons; 24-hour correction/redelivery

Commits; states 24 hours (Sec. 7.0)

Covered

None.

8.1–8.2.1

EFT payment; adhere to SAM; if not registered, award to next registered offeror

Commits to active SAM and EFT (Sec. 3.0)

Covered

None.

Return one complete copy of entire solicitation package (SF-1449, Sections B–M, reference sheet); email quote; do not call to confirm receipt

Administrative submission

States submission intended to be complete; acknowledges return of complete package; will email; will not call to confirm receipt (Sec. 1.0)

Covered

Ensure actual package includes SF-1449 + all required attachments and completed checkboxes.

Insert quote amount in Block 26, SF-1449; Base Work Item price includes taxes (no tax exemption certificate)

Pricing/admin

Provides FFP line with taxes included; acknowledges no tax exemption (Sec. 2.0)

Partially Covered

Proposal shows blank price line; does not explicitly confirm Block 26 is completed (though implied).

Provide UEI, Tax ID, CAGE fields

Administrative data

Provides UEI/Tax ID/CAGE placeholders (Sec. 3.0)

Partially Covered

Fields are blank in provided text; ensure completed on submission.

Mark correspondence/submittals with solicitation number 70Z03026QCLEV0055 (Section D-1)

Administrative

Explicitly commits to marking with solicitation number (Sec. 1.0; Sec. 8.0)

Covered

None.

After award: include contract number 70Z03026PCLEV0055 in subject line (G-3)

Contract admin

Explicitly commits (Sec. 1.0; Sec. 8.0)

Covered

None.

IPP invoicing; courtesy copies to CO/CS/COR; web submission confirmation not acceptance (G-1)

Invoicing

Commits to IPP use; includes courtesy emails; acknowledges confirmation not acceptance (Sec. 1.0; Sec. 8.0; Sec. 3.0)

Covered

Proposal includes the correct named emails.

SAM registration required; UEI recorded on every invoice; EFT payment (G-2; SOW 8.1/8.2)

Payment/compliance

Commits SAM active; UEI on every invoice; EFT alignment via FAR 52.232-33 references (Sec. 3.0; Sec. 8.0)

Covered

None.

SOW 1.2: Continuously provide 6 individual hotel rooms; transfer days approx every other Thursday; rooms ready same day; individual bedrooms & bathrooms required

SOW performance

Commits to continuously hold 6 rooms; transfer-day readiness same day; individual bedrooms/bathrooms; no shared (Sec. 2.0; Sec. 4.0)

Covered

None.

SOW 2.1 & 2.12: Rooms grouped together; away from high noise/traffic; immediate vicinity of each other for coordination

SOW performance

Commits to group rooms as much as possible; away from noise/traffic (Sec. 4.0)

Partially Covered

Uses 'as much as possible' but does not explicitly address 'immediate vicinity of each other' (though implied). Consider explicit commitment to SOW 2.12.

SOW 2.2/4.0: MUST be within max 40-minute response; calculated using Google Maps from accommodations address

SOW performance

Commits to comply; references Google Maps calculation (Sec. 4.0)

Partially Covered

Does not provide the actual lodging address or a specific verified travel-time screenshot/printout.

SOW 2.3: Cable television and internet

SOW performance

Commits to provide both; includes escalation path for outages (Sec. 4.0)

Covered

None.

SOW 2.4: Fully furnished; utilities included; refrigerator and microwave

SOW performance

Commits to furnishing list; utilities included; refrigerator and microwave (Sec. 2.0; Sec. 4.0)

Covered

None.

SOW 2.5: Linens weekly; towels daily/as needed

SOW performance

Commits linens weekly; towels daily/as needed; logs available (Sec. 5.0)

Covered

None.

SOW 2.6: Minimum of 2 vehicle parking spots

SOW performance

Commits at least 2 spots at all times (Sec. 6.0)

Covered

None.

SOW 2.7–2.11: Structural soundness; no mold/odors/infestation; no water/dirt/stains/damage; appliances/HVAC clean & working; exterior walls clean

SOW performance

Commits to structural condition, mold/odor/pest-free, appliances/HVAC maintenance, exterior wall cleanliness (Sec. 4.0; Sec. 6.0)

Covered

None.

SOW 2.13: Safe, quiet, peaceful neighborhood free of frequent disputes/illegal activity

SOW performance

Commits to safe/quiet/peaceful and mitigation/relocation if needed (Sec. 6.0)

Covered

None.

SOW 3.0: Period of performance 22 May 2026 to 08 Sep 2026 (SOW text) / Background references 22 Jun 2026 to 08 Sep 2026

SOW schedule

Proposal references performance period 'specified in SOW' but does not state dates; does mention SOW dated 05 JUN 2026 (Sec. 2.0; Sec. 4.0)

Partially Covered

Risk: SOW contains an internal inconsistency (22 May vs 22 Jun start). Proposal does not clarify which dates are priced/covered.

SOW 5.0 & 6.0: Government furnishes no resources; contractor furnishes all

SOW admin/performance

Explicitly states Government will not furnish resources; contractor responsible for all (Sec. 8.0)

Covered

None.

SOW 7.0–7.2: COR acceptance email; rejection reasons; 24 hours to correct and redeliver

Acceptance/QA

Commits to QA/inspection; acknowledges COR rejection/correction; explicitly states 24 hours (Sec. 7.0)

Covered

None.

E-1 FAR 52.246-4 Inspection of Services-Fixed-Price

Maintain inspection system acceptable to Government; keep complete records; reperform at no increase if nonconforming; Gov can reduce price/terminate

Describes inspection system, records, corrective actions, reperformance at no increase; references FAR 52.246-4 (Sec. 5.0; 7.0)

Covered

None.

E-2 FAR 52.246-15 Certificate of Conformance

If authorized in writing by CAO, ship with signed Certificate of Conformance; include on receiving report; Gov right to reject remains

Not mentioned

Gap

Low/Medium likelihood for service lodging; but clause is present—proposal should acknowledge ability to provide CoC if directed.

F-1 FAR 52.211-16 Variation in Quantity (0% inc/dec)

No variation accepted beyond stated (0%/0%)

Not mentioned

Gap

Potential dispute risk if Government expects strict adherence to 6 rooms continuously without deviation.

G-1 IPP invoicing + courtesy copy emails

Invoice via IPP; courtesy copies to CO/CS/COR; routing symbol; IPP receipt not acceptance

Fully addressed (Sec. 8.0; 1.0; 3.0)

Covered

Add explicit mention of changing routing symbol when invoicing other USCG offices (optional best practice).

G-3 Correspondence: send to CO; copy Contract Specialist; contract number in subject line

Communication routing requirements

Commits to direct to CO; copy CS; include identifiers (Sec. 8.0; 13.0)

Covered

None.

H-2 Required Insurance (15 days after award/prior to work; maintain coverage; specified limits)

Provide certificate; meet limits for WC/GL/Auto/PD; maintain through POP

Commits to provide COI within 15 days/prior to work; maintain; describes coverages (Sec. 9.0)

Partially Covered

Proposal does not restate the exact dollar limits (e.g., GL $500k/occ; Auto $500k/occ, $200k/person; PD $20k).

H-3 Modification Proposals – Price Breakdown

Provide itemized breakdown (material, labor, equipment, subcontracts, overhead, profit) + time-extension justification

Commits to provide itemized breakdown and schedule justification (Sec. 2.0)

Covered

None.

H-4 FAR 52.234-4 Earned Value Management System (EIA-748); submit reports; IBR; accreditation/surveillance; subcontract flowdown list

EVMS obligations if applicable; potentially significant compliance burden

Not mentioned

Gap

High risk of noncompliance if CO enforces clause as written (even if seemingly inapplicable to lodging). Seek clarification/waiver or state EVMS approach/exemption rationale.

H-5 HSAR 3052.223-70 Hazardous substances removal/disposal: have/obtain licenses and permits; provide evidence prior to work

If performing hazardous substance removal/disposal, provide permits; obtain within 0 days if missing

Not mentioned

Gap

May be inapplicable to lodging; but present. Risk if contractor performs disposal of regulated materials (e.g., mold remediation, refrigerant disposal) without permits.

I-2 HSAR 3052.204-70 IT Security Plan + accreditation (if IT resources connected to DHS network or access to DHS sensitive info on unclassified systems)

Submit IT Security Plan within X days (blank); accreditation within 6 months; return/purge info at expiration

Proposal provides general sensitive information training and non-disclosure commitments; does not address IT Security Plan/accreditation deliverables (Sec. 10.0)

Partially Covered

If any DHS IT access occurs, proposal lacks plan submission commitment, purge/certification language, and accreditation proof requirement.

I-2 HSAR 3052.204-71 Contractor employee access (forms, fingerprinting, background checks; nondisclosure; training; flowdown; citizenship reporting in alternates)

Comply with access controls; training; flowdown; identify non-U.S. citizens if required (Alt I/II)

Commits to comply with access/credentialing/background checks and training; flowdown to subs (Sec. 10.0)

Partially Covered

Does not address non-U.S. citizen identification/reporting obligations (Alt I/II) or security briefing/NDA steps if IT access is granted.

I-2 HSAR 3052.209-72 Organizational conflict of interest (OCI) disclosure/mitigation plan if applicable; flowdown for first-tier subcontracts > SAT

Offeror must represent either no OCI or disclose and provide mitigation plan

Not mentioned

Gap

OCI representation is explicitly required by the clause text; omission increases responsiveness risk unless satisfied via completed solicitation checkboxes/attachments.

Section K representations/certifications (multiple checkboxes: lobbying, internal confidentiality agreements, inverted domestic corp, ownership/control, etc.)

Complete and submit representations (often via SF-1449/ORCA/SAM + solicitation blocks)

States that signed SF-1449 and returned package includes completed reps/certs (Sec. 12.0)

Partially Covered

Narrative asserts completion but does not show completed K provision blocks (e.g., FAR 52.204-17 ownership/control; FAR 52.209-2; HSAR expatriate disclosure). Ensure included artifacts.

J-2 RFI Sheet: submit questions on form to Jonathan.C.Barrett@uscg.mil no later than 5 working days prior to closing

RFI submission process

Acknowledges RFI process and deadline (Sec. 12.0)

Covered

None.

Period of performance ambiguity (SOW internal inconsistency May vs June start) not explicitly priced/confirmed

SOW 1.1 (22 Jun 2026–08 Sep 2026) vs SOW 3.0 (22 May 2026–08 Sep 2026)

Proposal does not state dates; references 'period specified in SOW'

High (pricing scope/availability risk; performance start disputes)

State the exact POP dates your price covers; request clarification via RFI if needed; include assumption statement referencing the controlling section/date.

EVMS clause not addressed

H-4 FAR 52.234-4

No EVMS mention

High (if enforced: major compliance burden; reporting/IBR obligations)

Add a compliance statement: either confirm EVMS capability (EIA-748 compliant) and reporting readiness or request applicability clarification/waiver given lodging scope.

OCI disclosure/representation not evidenced

HSAR 3052.209-72 / 3052.209-73

No OCI statement or mitigation plan

Medium/High (responsiveness risk if clause requires explicit representation/attachment)

Include explicit representation: no known actual/potential OCI; if any potential exists, provide disclosure and mitigation plan; confirm flowdown if subcontracting > SAT.

Certificate of Conformance clause handling absent

E-2 FAR 52.246-15

Not discussed

Low/Medium (often supply-shipment oriented; but clause included)

Add statement that contractor can provide a signed Certificate of Conformance when authorized/directed by CAO/CO, using the prescribed language.

Insurance limits not explicitly matched to solicitation amounts

H-2 Required Insurance

Commits to provide COI and types of insurance but does not restate limits

Medium (award admin friction if COI limits insufficient)

Restate required minimum limits (GL/Auto/PD) and confirm your current policy meets/exceeds them; note any deductibles if relevant.

40-minute response requirement lacks objective evidence (address + Google Maps calculation)

SOW 2.2/4.0

Commitment only; no address or map evidence

Medium (evaluation risk; potential elimination if CO requires proof)

Provide accommodations address and attach Google Maps travel-time evidence; include statement that the route is within 40 minutes from hotel exit under typical conditions.

Immediate vicinity requirement not explicitly guaranteed

SOW 2.12

Says 'group together as much as possible'

Medium (operational coordination risk; may be evaluated strictly)

Add explicit commitment: all six rooms will be in the same property and immediate vicinity (same building and proximate placement) unless Government approves deviation.

Representations/certifications reliance on 'included in package' without visible completion

Section K multiple provisions; SF-1449 completion

Narrative says completed; placeholders remain blank in text

Medium (non-responsiveness risk if any required blocks are incomplete)

Ensure all Section K checkboxes/blocks are completed (e.g., FAR 52.204-17, 52.209-2, HSAR expatriate disclosure) and cross-reference by listing included forms/attachments in a compliance checklist.

IT/security clause deliverables (IT Security Plan, purge/certification) not addressed beyond general training

HSAR 3052.204-70 / 3052.204-71

General sensitive info protection; no IT Security Plan/accreditation language

Low/Medium (depends on whether contractor accesses DHS IT/sensitive systems)

Add conditional compliance language: if any DHS IT access/connection occurs, contractor will submit an IT Security Plan for approval, support accreditation artifacts, and certify purge/return of non-public info at contract end.

R-01

Pricing/availability dispute at start of performance

SOW start date inconsistency not clarified in proposal

Medium

High

Explicitly state assumed POP start/end dates; seek CO clarification if needed; ensure room-hold commitments align to dates.

R-02

Post-award noncompliance finding related to EVMS

H-4 EVMS clause not addressed; contractor may lack EIA-748 compliant system

Low/Medium

High

Clarify applicability; if applicable, provide EVMS compliance statement and reporting approach; otherwise request waiver/confirm non-applicability.

R-03

Elimination as non-responsive due to missing certifications/blocks

Section K requires completed representations/checkboxes; proposal text uses placeholders

Medium

High

Provide a submission compliance matrix listing each required form/provision and confirming completion/attachment.

R-04

Evaluation downgrade or rejection due to unproven 40-minute response time

No address/map evidence provided

Medium

Medium/High

Attach Google Maps calculations from lodging address to AIRFAC address; include assumptions and confirm no location changes without CO approval.

R-05

Operational coordination issues for duty crew

Immediate vicinity requirement stated in SOW; proposal uses 'as much as possible'

Medium

Medium

Commit to same wing/floor block; define what 'grouped' means (e.g., contiguous rooms) and how maintained across turnovers.

R-06

Administrative delay in invoice payment

Routing symbol/IPP/SAM issues; UEI omission on invoice

Low

Medium

Include invoice content checklist; confirm routing symbol verification step; ensure UEI appears on every invoice.

R-07

Insurance acceptance delay

COI provided but limits may not meet H-2 minimums

Medium

Medium

State policy limits meet/exceed H-2; include carrier, policy numbers, and limits summary in proposal attachments.

R-08

Security/access compliance findings if DHS IT access is introduced

HSAR 3052.204-70/71 require specific actions; proposal only general

Low

Medium

Add conditional IT/security compliance commitments (plan submission, NDA/briefing, purge certification, non-U.S. citizen disclosure if applicable).

Add an explicit 'Period of Performance & Pricing Assumptions' paragraph

SOW 1.1 / SOW 3.0

State the precise dates your firm-fixed price covers; note handling if SOW dates are corrected by amendment; confirm continuous hold of 6 rooms for entire POP

Prevents scope disputes; strengthens responsiveness and price reasonableness evaluation.

Provide accommodations address and 40-minute compliance evidence

SOW 2.2 / 4.0

Insert address; attach/describe Google Maps results showing <= 40 minutes; specify time-of-day basis and route

Reduces evaluation uncertainty and risk of rejection for unmet mandatory requirement.

Commit explicitly to 'immediate vicinity' standard

SOW 2.12

Replace/augment 'as much as possible' with a firm commitment to proximate placement (same property, same floor/wing) unless Government approves exception

Improves compliance clarity for duty crew coordination requirement.

Add EVMS clause position statement

H-4 FAR 52.234-4

Either (a) confirm EVMS capability and willingness to comply with EIA-748 reporting/IBR, or (b) request CO determination of non-applicability for this services buy and propose an alternative reporting method if required

Mitigates high-impact compliance surprise post-award.

Add OCI representation and (if needed) mitigation approach

HSAR 3052.209-72/73

Include explicit representation: no known OCI/unfair competitive advantage; describe internal process to identify/avoid OCI; confirm flowdown to first-tier subs > SAT

Reduces non-responsiveness and later disqualification risk.

Add Certificate of Conformance acknowledgment (conditional)

E-2 FAR 52.246-15

State ability to provide a signed Certificate of Conformance if authorized in writing by CAO/CO, using required wording

Closes a clause-driven documentation gap.

Restate required insurance limits and confirm compliance

H-2

Include a limits table matching H-2 amounts and confirm your policies meet/exceed; indicate COI will name required additional insureds if required by CO

Reduces award admin friction and risk of delayed start.

Include a 'Submission Compliance Checklist' attachment list

Instruction to return entire solicitation package; Section K; Section J

List each returned document: signed SF-1449, Sections B–M, J-2 RFI (if any), J-3 Reference Info Sheet, completed K representations, any other required forms

Makes completeness auditable; reduces non-responsive determination risk.

Expand IT/sensitive information handling to include purge/return and NDA/briefing language (conditional)

HSAR 3052.204-70/71 (and alternates if invoked)

Add: end-of-contract return/purge certification; comply with DHS NDAs and security briefings before IT access; identify/report non-U.S. citizens if any are proposed (if applicable)

Improves clause-level compliance posture if DHS access requirements are triggered.