VA Boiler Plant Services Proposal Compliance Gap Analysis

Shift scheduling

Shift established 2 weeks in advance; subject to change at Boiler Plant Supervisor discretion

Commits to coordinate schedules 2 weeks in advance with VA Boiler Plant Supervisor

Covered

Add statement acknowledging VA may change schedule and contractor will accommodate.

40 hours/week per operator

40 hours/week for 52-week PoP unless exception approved by COR

Does not explicitly restate 40 hours/week per operator; references full-time shifts and billing by actual hours

Partially Covered

Add explicit commitment to 40 hours/week/operator unless COR-approved exception.

Overtime rules

Notify COR prior; obtain approval; invoice time-and-a-half; no night/holiday differential

Explicitly states notify COR in advance, obtain approval; time-and-a-half; no night/holiday differentials

Covered

None.

Parts/materials

VA provides materials for repairs upon written request

Acknowledges VA provides materials upon written request; contractor provides labor/expertise

Covered

Add process for written request submission/format (email/work order) if known.

Use of government equipment

Do not open desks/cabinets or use office equipment except as required; only authorized systems

Commits not to open desks/cabinets; limits system access to authorized plant systems; no patient info

Covered

None.

Performance deficiencies & corrective action

Deficiencies documented via CDR/Cure Notice; contractor must correct within specified timeframe; notify CO/COR when corrected

States deficiencies will be corrected within government timeframes and contractor will notify CO/COR upon completion

Covered

Consider adding internal RCA/CAPA method (optional but strengthens).

Surveillance

Random monitoring; acceptance testing witnessed by Boiler Plant Supervisor/designee

Acknowledges random monitoring and acceptance testing witnessed; commits to transparent performance

Covered

None.

B.1 Contract Administration Data

Complete and return all designated info prior to SF1449 Block 8 time

Includes B.1 section with amendment acknowledgment table; contractor admin info fields; government POC narrative

Partially Covered

Fields are present but appear blank placeholders; ensure completed values and returned as part of final submission package.

B.3 SOW – Staffing (6 operators; rotating shifts; 24/7 operations)

Provide six qualified stationary engineers/operators for coverage across shifts; campus operates 24/7

Commits to providing six fully qualified stationary engineers/operators; rotating shifts incl. weekends/holidays; acknowledges 24/7/365 mission critical ops

Covered

Add explicit linkage that staffing supports all buildings listed in Attachment 1 (already implied).

B.3 SOW – Mobilization within 30 days

Six fully qualified staff working full-time shifts within 30 days of award; failure may be default

Explicit commitment to mobilize within 30 days and acknowledges default risk; describes mobilization plan

Covered

Consider adding measurable internal milestones (no timeline required, but responsibilities/controls).

B.3 SOW – Licensing & resumes

Valid City of Chicago Stationary Engineer’s License; submit resume PDF proving 3 years experience; include copies of licenses for proposal evaluation

States all personnel will hold license, 3 years experience; will submit resumes PDF; will include copies of licenses with proposal

Covered

Ensure at least 3 resumes/licenses included per Section E addendum.

B.3 SOW – 40-hour pairing & 8-operator cap

Each operator pairs 40 hours with qualified VA operator; Government pays up to 8 different operators; beyond is contractor cost

Commits to 40-hour pairing; recognizes up to 8 operators inclusive alternates; states stability focus

Covered

Add how tracking will be maintained to ensure not exceeding 8 billable pairings.

B.3 SOW – Safe Steaming 1 & 2 training

Complete VA Safe Steaming 1 & 2 prior to starting work

Explicitly acknowledges and commits; plans as onboarding prerequisite

Covered

None.

B.3 SOW – PPE & OSHA/NFPA/ASME/VHA 1810 compliance

Provide specified PPE; OSHA HazCom (SDS) and NFPA 70E training; conform to ASME, NFPA 85, NFPA 70E, VHA 1810, testing manual v8

Commits to PPE items listed; HazCom and NFPA 70E; references VHA 1810 and Safety Device Testing Manual v8; ASME/NFPA standards

Covered

Solicitation requires OSHA-approved steel toe meeting 29 CFR 1910.136 and ANSI Z41.1-1967—proposal states OSHA-compliant; consider citing the ANSI spec explicitly.

B.3 SOW – Two-week assessment report (PE)

Every 2 weeks written report using Attachment 4; assessor must be PE + 3 years VA ops + knowledge of 1810 & manual v8

Dedicated section committing to 2-week cadence; assigns PE with active license; states 3 years VA ops experience and knowledge

Covered

Ensure proposal includes PE license documentation + experience proof per submission instructions.

Reporting/Documentation

Daily check-in/out; detailed written reports; weekly email timecards for approval; emergency contacts

Commits to daily logs, check in/out, weekly timecards email for approval; provides 24/7 emergency contact list commitment

Covered

Confirm logs include all solicitation-required elements (exact location, itemized parts, equipment identifiers, names). Proposal includes these.

Emergency & safety device reporting

Immediate escalation call chain; immediate report of non-functioning safety devices + follow-up email + daily log documentation

Commits to escalation order and immediate safety device reporting with email follow-up and daily log entries

Covered

None.

Invoicing

Monthly in arrears; Tungsten Network; submit by 10th; include required invoice data; no fax/email/scans

Commits to monthly in arrears, Tungsten, by 10th; states invoice content; acknowledges no fax/email/scans

Covered

Include internal control: reconciliation to approved timecards/logs (already included).

Facility requirements

Parking, drug-free, container searches, smoking/weapon prohibition, VHA 1192 flu masking/vaccine + contractor provides masks/vaccines

Commits to parking compliance; drug-free; smoking/weapons prohibition; container search acknowledgement; commits to VHA 1192 and providing masks/vaccines

Covered

None.

Security & privacy controls

A&A not required; still must protect VA sensitive info; only authorized systems; privacy and infosec contact points

States A&A not applicable; commits to limit system access to authorized plant systems only; no patient info access; commits to coordinate with VA offices

Partially Covered

Proposal does not repeat the VA Privacy Service / OCS phone numbers (not required but helpful). Ensure internal incident reporting aligns with VA clause 852.204-72 lost/stolen requirements.

PIV / NACI / SAC

Tier 1 NACI + SAC fingerprints; fees contractor responsibility; PIV can take 2 days; return IDs; quarterly status report; lost/stolen reporting with 48-hour incident report

Commits to Tier 1 NACI + SAC; acknowledges fees contractor responsibility; accounts for 2 days labor; commits to return/track cards; commits to quarterly status reports; commits to report lost/stolen and incident reports (timelines referenced generally)

Partially Covered

Solicitation clause 852.204-72 requires incident report within 48 hours and quarterly status report within 5 working days after quarter end; proposal references quarterly reports but not the '5 working days' detail; proposal says “within required timelines” for incident report—tighten to explicit 48 hours.

Limitations on Subcontracting (VAAR 852.219-75)

Provide signed certificate with offer; comply with ≤50% to non-similarly situated; maintain records

Includes LOS narrative confirmation and includes the certificate fill-in block with signature lines (blank); commits to records

Partially Covered

Certification must be completed, signed, and returned with offer; proposal shows blanks. Ensure executed signature page included.

Section E – Submission instructions

Submit by email to eileen.meyer@va.gov; proposal must be self-sufficient; no external links

Commits to self-sufficient response without external links; mentions email size limit and splitting emails if needed

Partially Covered

Proposal does not explicitly state submission email address (it mentions splitting emails). Add explicit 'will submit to eileen.meyer@va.gov' statement for alignment.

E-ADD-PRICE-a

Price volume includes complete Schedule of Supplies/Services and Prices/Costs

States price proposal provided under separate attachment; states schedule included

Partially Covered

Not verifiable in provided text; ensure attachment is present and clearly labeled; cross-reference in proposal table of contents.

E-ADD-PRICE-b

Fill in SF1449 blocks 17a, 30a, 30b, 30c on page 1

States SF1449 signature blocks/required fields completed in separate attachment

Partially Covered

Ensure the actual SF1449 blocks are completed and signed; include as part of the proposal package.

E-ADD-PRICE-c

Contractor information on page 2 (SF1449 continuation)

Includes contractor admin info fields under B.1

Partially Covered

Ensure SF1449 page 2 contractor info is completed (not only narrative section).

E-ADD-PRICE-d

Completed clause fill-ins for VAAR 852.219-75 (signed certificate required for eligibility)

Includes VAAR 852.219-75 certificate block but blanks for signature/name/date/address

Gap

Complete and sign the certificate; omission risks rejection as ineligible.

E-ADD-PRICE-e

Completed provision fill-ins for FAR 52.204-24 (as applicable)

Includes FAR 52.204-24 representation with checkboxes not selected

Gap

Select the applicable boxes ('will/will not', 'does/does not') and provide disclosure if required. Unchecked boxes can fail strict compliance.

E-ADD-PRICE-f

Completed provision fill-ins for FAR 52.209-7

Includes FAR 52.209-7 statement with checkboxes not selected

Gap

Check 'has/does not have' and ensure consistency with SAM/FAPIIS obligations.

E-ADD-PRICE-g

Completed provision fill-ins for FAR 52.212-3

States annual reps/certs in SAM are current; references completion; does not include completed form text

Partially Covered

If relying on SAM annual reps, OK; but solicitation addendum asks completed provision fill-ins—confirm whether CO expects a completed 52.212-3 fill-in or a statement plus SAM proof.

E-ADD-PRICE-h

Completed Price Schedule

States completed price schedule included as distinct portion

Partially Covered

Not verifiable in provided text; ensure included and consistent with 'actual hours worked' billing.

E-ADD-PRICE-i

Certificate of Liability Insurance meeting CL-120 minimums and no asbestos exclusion

States COI included and meets minimums incl. no asbestos exclusions

Partially Covered

Not verifiable; ensure COI explicitly shows limits: GL $500k/occ; Auto $200k/$500k/$20k; WC/EL as required; and no asbestos exclusion language.

E-ADD-PRICE-j

Current and active SAM registration required; inactive SAM = nonresponsive

States proof of active SAM included; commits to maintain SAM active

Partially Covered

Include SAM status printout/date stamp and UEI matching proposal header.

E-ADD-PRICE-k

Current and active DSBS/SBA certification for SDVOSB eligibility; must be SBA-certified/listed

States SDVOSB certification evidence included; confirms eligibility and certification status

Partially Covered

Include proof of SBA certification/listing (solicitation references SBA verification). Ensure exact entity name matches SAM.

B1-AMEND

Acknowledge solicitation amendments (number and date)

Contains amendment acknowledgment table but blanks

Gap

Populate with all issued amendments (or 'None' if permitted) and ensure consistency with SF1449 amendment acknowledgement block.

E-EMAIL-LIMIT

Email submission size limit 7MB; split into multiple emails if needed

Acknowledges 7MB limit and will split emails

Covered

Add naming convention for multi-email parts to reduce risk of missing volumes (recommended).

CO authority / no unauthorized commitments

CO is sole authority for changes affecting price/quantity/quality

Provides strong, detailed acknowledgment and internal controls to prevent unauthorized commitments

Reduces performance/admin risk; supports confidence in contract compliance.

Log quality & turnover discipline

Daily logs, review prior shift, document significant actions

Provides detailed log content elements and structured turnover discussions

Supports surveillance/acceptance; demonstrates mature operations discipline.

Mobilization risk awareness

Must staff within 30 days or risk default

Explicitly acknowledges default risk and describes pipeline controls

Demonstrates understanding and risk mitigation.

Invoice audit readiness

Monthly e-invoicing with required data and supporting documentation

Adds reconciliation against approved timecards/logs; audit-ready procedures

Reduces payment disputes and compliance issues.

Facility conduct compliance

Drug-free, no smoking, no weapons, parking rules, VHA 1192

Covers all and adds contractor-provided masks/vaccines commitment

Reduces risk of facility violations/material breach.

R-001

Responsiveness / Administrative

Unchecked checkbox fill-ins for FAR 52.204-24 representation

High

High

Addendum requires completed provision fill-ins; strict compliance review may reject incomplete representations.

R-002

Responsiveness / Administrative

Unchecked checkbox fill-ins for FAR 52.209-7 responsibility matters

High

High

Explicitly required in E.8 initial compliance review; missing/unchecked may be treated as failure to furnish required reps.

R-003

Eligibility / Set-aside compliance

VAAR 852.219-75 certificate signature block appears unexecuted

High

Critical

Clause text states government will not consider offers without the signed certification; proposal could be deemed ineligible.

R-004

Responsiveness / Amendment acknowledgment

Amendment numbers/dates not populated

Medium

High

B.1 requires completion prior to Block 8 time; missing amendment acknowledgement can render offer nonresponsive.

R-005

Security/PIV compliance precision

852.204-72 timelines not explicitly mirrored (48-hour incident report; quarterly report within 5 working days)

Medium

Medium

Government may scrutinize PIV admin; noncompliance can delay final payment and trigger corrective action.

R-006

SOW coverage completeness

40 hours/week per operator not explicitly confirmed (unless exception approved by COR)

Medium

Medium

SOW includes specific hours-of-coverage expectation; omission could raise evaluator questions on staffing realism.

R-007

Proof/Attachment dependency

Multiple items asserted as “included under separate attachment” (price schedule, SF1449, COI, SAM proof, SBA/SDVOSB proof) not verifiable from narrative

Medium

High

Solicitation warns missing/incomplete items may render proposal ineligible; ensure attachment index and clear labeling.

REC-001

Complete all solicitation-required checkbox representations in the proposal package (at minimum: FAR 52.204-24 and FAR 52.209-7) and ensure internal consistency with SAM annual reps.

E.3 (52.204-24); E.5 (52.209-7); E.8 strict compliance review

Prevents nonresponsive determination due to incomplete reps/certs.

REC-002

Execute (sign/date) VAAR 852.219-75 Certificate of Compliance and ensure company name/address match SAM exactly.

VAAR 852.219-75; Addendum required documentation item (d)

Avoids ineligibility for award on SDVOSB set-aside.

REC-003

Populate B.1 amendment acknowledgment numbers/dates (or state 'No amendments' if applicable per SF1449 practice) and cross-check SF1449 amendment block for consistency.

B.1 Acknowledgment of Amendments

Reduces risk of rejection for failure to acknowledge amendments.

REC-004

Add an explicit statement committing to 40 hours/week per operator (unless COR-approved exception) and that VA may change shifts at supervisor discretion; confirm contractor will accommodate without lapse in coverage.

B.3 Hours of Coverage; scheduling provisions

Improves evaluator confidence in staffing realism and SOW conformance.

REC-005

Tighten PIV/lost-stolen and quarterly reporting language to match clause 852.204-72 (incident report within 48 hours; quarterly status report within 5 working days after quarter end) and include a brief internal tracking/control description.

852.204-72 (f) and (g)

Reduces compliance risk and risk of delayed final payment.

REC-006

Provide an attachment index/crosswalk (one-page) listing each required submission artifact and where it is found (file name, section, page).

Addendum to 52.212-1 Required Documentation; E.8 strict compliance review

De-risks strict compliance screening; reduces chance of evaluator missing an attachment.

REC-007

Ensure COI evidence explicitly shows CL-120 minimum limits and states no asbestos exclusion that would void coverage; reference the exact COI endorsement language in the proposal.

CL-120 Supplemental Insurance Requirements

Prevents award delays or rejection due to insurance ambiguity.

REC-008

Explicitly state proposal submission will be emailed to eileen.meyer@va.gov and include a packaging convention for multi-email submissions (e.g., Volume labels/Part numbers) to comply with the 7MB limit without missing files.

Addendum to 52.212-1 Required Documentation; email size limitation

Reduces delivery/administrative risk.

REC-009

Where the proposal references ‘will submit’ supporting documentation (resumes/licenses/PE credentials), confirm included items meet the minimum counts (≥3 resumes/licenses) and label them to match the evaluation factor headings (Technical Capability/Experience/Past Performance).

Addendum Technical Capability; Experience; Past Performance

Improves evaluation usability and reduces compliance questions.