VA Fire Alarm & Protection Proposal Compliance Gap Analysis

Solicitation Number / Date

36C26226Q0840 / 06-04-2026

References 36C26226Q0840 and 06-04-2026

Covered

Set-aside / Eligibility

Total set-aside for certified SDVOSB (VAAR 852.219-73)

States certified SDVOSB and material eligibility

Covered

Award basis

FAR Part 13; lowest price reasonable within funding + responsibility standards

Acknowledges FAR Part 13 and LPTA-style basis

Covered

Contract type

Firm-Fixed-Price (52.216-1)

States firm-fixed-price offer

Covered

Performance sites

LAACC (351 E Temple) + Sepulveda (16111 Plummer) buildings list

Correctly describes 1 LAACC + 19 Sepulveda buildings and addresses

Covered

Annual fire alarm inspection & testing all buildings within 30 days of award; reports within 60 days

SOW B.1

Commits to complete annual fire alarm inspection/testing within 30 days and submit reports within 60 days

Covered

Aligns directly.

Annual sprinkler inspection/testing/reporting within 45 days of award

SOW B.2

Commits to deliver initial sprinkler inspection results/reports within 45 days of award

Covered

—

Quarterly sprinkler inspections: perform within first month of each quarter; reports before end of second month

SOW B.3

Commits to perform within first month; submit before end of second month

Covered

—

Annual fire pump inspection/testing/reports within 60 days of award

SOW B.4

Commits to perform annual fire pump testing and provide documentation within 60 days

Covered

—

Provide one annual TJC report within 60 days for Buildings 10, 99, 200, & LAACC

SOW B.5

Commits to consolidated TJC compliance-ready package within 60 days for Buildings 10, 99, 200, and LAACC

Covered

—

Take over existing cellular dialers; provide programming and monthly service within 15 days for specified 14 buildings

SOW B.6

Commits to assume responsibility for existing dialers, programming as needed, pay monthly service; transition within 15 days

Partially Covered

Does not explicitly restate the exact building list for dialers (though generally aligned); include explicit list match.

Provide 24/7/365 monitoring by UL Listed Central Station; contractor bears cost; billed in arrears after end of each quarter

SOW B.7

Commits to UL-listed central station monitoring, contractor bears cost; mentions quarterly billing requirement but also references solicitation monthly invoicing instruction

Partially Covered

Potential billing cadence conflict: SOW says quarterly for monitoring; Section B says monthly invoicing in arrears (overall). Clarify invoicing structure by CLIN.

Semiannual visual inspection 180 days from annual inspection (specific elements)

SOW B.8

Commits to calendar and perform semiannual visual inspections; lists required elements (trouble signals, annunciators, initiating devices, notification appliances, batteries)

Covered

—

Emergency response within 2 hours; means of notification by mutual agreement

SOW B.9

Accepts 2-hour emergency response; notes notification means by mutual agreement; provides contact structure

Covered

—

Initial survey/visual inspection at beginning; inspect listed component categories; written deficiency report + proposal w/cost within 14 days

SOW A.7

Commits to initial survey baseline inventory; deficiency notice with NFPA/AHJ reference; proposal with cost within 14 days

Covered

—

LAACC Reg 4 annual inspection/testing/reporting includes sprinkler, standpipe, fire pump, emergency generator, elevator

SOW A.4(a)

Acknowledges Reg 4 elements inclusive of sprinkler, standpipe, fire pump, generator, elevator interfaces

Covered

—

Verify reliable operation; conform to NFPA + manufacturer recommendations; meet EC 02.03.05 EP 1-4

SOW Scope text

Commits to verify reliable operation; NFPA 72/25; references Joint Commission and EC.02.03.05

Covered

—

Use VA-supplied testing checklist forms for inventory/survey; submit to Compliance Officer and Facility Manager

SOW A.5

Commits to use VA-supplied forms and submit to Compliance Officer and Facility Manager

Covered

—

Arrange site visits through Engineering Facility Manager; no site visits without prior notification

SOW A.6

Explicitly states will not commence site work without arranging visit through Facility Manager/Engineering Supervisor

Covered

—

Notify alarm recipients and occupants before testing; notify Engineering and monitoring company when system out of service and when returned

SOW A.6

Commits to occupant/POC notification and coordination with Engineering and monitoring company for test/out-of-service/restore

Covered

—

Normal working hours 7:00am–4:30pm excluding federal holidays unless authorized

SOW Period of Performance

Commits to routine testing within 7:00am–4:30pm excluding federal holidays unless authorized

Covered

—

Overtime/holiday pay is contractor responsibility; not billable

SOW Overtime & Holiday Pay

Explicitly acknowledges not billable to Government

Covered

—

Contractor will be paid for actual services; not paid for availability/on-call unless provided

SOW 4(c)

Discusses emergency response and on-call coverage but does not explicitly acknowledge 'no pay for availability' concept

Partially Covered

Add explicit statement to prevent misunderstanding about standby charges.

Contractor must be compliant with quarterly/annual inspections and verify previous inspection reports

SOW after holiday section

Mentions compliance and documentation focus; does not explicitly address verifying previous inspection reports

Partially Covered

Add explicit plan for review/verification of prior reports at transition.

Submit electronically to david.odne@va.gov by due date/time; label submission with contractor name/address, solicitation #, POC name/phone/email

Addendum 52.212-1 (Submittal Instructions)

No explicit statement of submission email, labeling, or POC email/phone block for submission package

Gap

May be deemed non-responsive if the package is not labeled/organized as required.

No Zip files; no facsimile offers

Addendum 52.212-1 (bullets)

Not mentioned

Gap

Operational submission risk (packaging).

Submit only one offer addressing all requirements

Addendum 52.212-1

Implicit (proposal addresses scope broadly) but not explicitly stated

Partially Covered

Add explicit statement to avoid ambiguity.

Three separate files required (File #1 pricing/SF1449 completion; File #2 CEP 10091 confirmation email; File #3 proof of licenses/certs/Reg4 account)

Addendum 52.212-1 (Content Organization)

Proposal narrative references intention to include proof and CEP confirmation, but does not provide the 3-file structure or attachments

Gap

High risk of exclusion: solicitation states deviation may exclude; missing attachments can preclude evaluation.

File #1: Pricing in Section B of SF1449; complete SF1449 blocks 12, 17a (include UEI), 30a/30b/30c; include SF30 amendments if issued

Addendum 52.212-1 (File #1)

Mentions UEI and SF1449 completion generally, but no actual completed SF1449 blocks or pricing

Gap

High risk: preliminary review may stop evaluation if blocks/pricing absent.

Acknowledgment of amendments (SF30 if any)

B.1 + 52.212-1(b)(9)

States will acknowledge amendments, but no amendment list/acknowledgment provided

Partially Covered

If amendments exist, omission is typically disqualifying.

File #2: CEP 10091 registration confirmation email included at time of offer

Addendum 52.212-1 + Basis for Award

States will include required confirmation as part of offer package

Partially Covered

Must attach actual confirmation email to avoid failing special standard of responsibility.

File #3: Proof of C-10, C-16, Reg 4 certification, active Reg 4 account

SOW A.1 + Addendum 52.212-1 (File #3)

States will provide proof with offer submission

Partially Covered

Must attach copies/evidence; narrative alone may be insufficient.

Include technical description sufficient to evaluate compliance

FAR 52.212-1(b)(4)

Detailed technical approach and schedule aligned with SOW

Covered

—

Past performance info when included as an evaluation factor (recent/relevant contracts, POCs, phone #s)

FAR 52.212-1(b)(10); solicitation evaluation notes using PPIRS/FAPIIS

Mentions will provide references for Siemens/Notifier/Edwards experience, but does not provide actual past performance projects/contracts

Gap

May weaken responsibility determination even if PPIRS/FAPIIS is primary source.

Include statement specifying extent of agreement with all solicitation terms if not using SF1449

FAR 52.212-1(b)(11)

States offer submitted without exception to solicitation terms and conditions

Covered

—

Conduct reasonable inquiry to ensure no prohibited covered telecom/video surveillance equipment/services (889) and no Kaspersky; comply during performance

52.240-91(f) + prohibitions

States will ensure equipment/services used comply and will conduct reasonable inquiries

Partially Covered

Add explicit statement that company does not use/provide covered telecom equipment/services (or disclose per 52.240-90(g)).

Quarterly SAM review for new FASCSA orders (at least once every three months) during performance

52.240-91(i)(1)

Not addressed

Gap

Add compliance procedure (supply chain review cadence, responsible role, recordkeeping).

72-hour reporting requirement if prohibited product/service is identified or notified

52.240-91(h)

Not addressed

Gap

Add incident/reporting SOP and CO notification commitment within 72 hours.

Flowdown of security prohibitions clause substance to subcontracts (per clause requirements)

52.240-91(j)

States will ensure subcontractors comply with flow-down requirements including security prohibitions clause substance

Covered

—

Offeror reps/certs under 52.240-90 (covered telecom use; FASCSA; Sudan; Iran) with disclosure process if cannot represent compliance

52.240-90

Not explicitly included as a reps/certs section; only a general commitment to comply with prohibitions

Gap

Add a signed reps/certs statement or confirm completion in SAM and state 'no disclosures required' (or provide disclosures within 72 hours if needed).

Do not engage in racially discriminatory DEI activities; provide records access; report subcontractor violations; flow down clause

FAR 52.222-90

Not mentioned

Gap

Add explicit clause compliance statement and subcontract flowdown commitment consistent with 52.222-90(c).

Monthly invoicing in arrears; electronic invoice via VA FSC/Tungsten; comply with VAAR 852.232-72

Section B.1 + SF1449 + 852.232-72 + Tungsten instructions

Commits to monthly invoicing in arrears via Tungsten and compliance with 852.232-72

Covered

—

Monitoring cost billed in arrears after end of each quarter (SOW)

SOW B.7

Mentions quarterly billing requirement but also frames as consistent with monthly invoicing instruction

Partially Covered

Clarify invoicing: monthly invoice for inspection/testing CLINs vs quarterly invoice for monitoring CLIN (0003) to match SOW.

Supplemental insurance minimums and asbestos exclusion prohibition; evidence prior to award

C.5 Supplemental Insurance Requirements

Commits to provide evidence prior to award; mentions no asbestos exclusionary clauses

Covered

—

Insurance certification within 15 days of award; must not contain 'will endeavor' wording; 30-day notice cancellation requirement

SOW 11(d)

Mentions will provide evidence prior to award; does not address 15-day post-award official certification requirement or 'will endeavor' prohibition

Partially Covered

Add explicit commitment to provide official insurer certificate within 15 days and that cert will not contain unacceptable wording.

EFT via SAM (52.232-33) and SAM maintenance (52.204-13)

B.1 + clause list

States will maintain active SAM registration and accurate reps/certs

Covered

—

CA Contractor License C-10 and C-16 (proof with bid)

SOW A.1; Addendum File #3; Basis for Award

States will provide proof with offer

Partially Covered

Attach license copies and status/expiration dates.

LA City Reg 4 certification and Active Reg 4 account with LAFD

SOW A.1; Addendum File #3

States will provide Reg 4 certification and active account proof

Partially Covered

Attach Reg 4 certificate, account letter/screenshot, and vendor ID/account number if applicable.

5 years Siemens certified installation/programming + references/phone #s

SOW A.2

States will provide documentation and references/phone numbers

Partially Covered

Attach certifications, resumes, and reference table.

5 years Notifier certified installation/programming + references/phone #s

SOW A.2

Same as above

Partially Covered

Attach.

5 years Edwards certified installation/programming + references/phone #s

SOW A.2

Same as above

Partially Covered

Attach.

Technical SOW execution

Proposal closely mirrors NFPA/TJC/Reg4 tasks, schedules, 2-hour response, dialer takeover, UL monitoring

Minor: explicitly list dialer-serviced buildings; verify previous reports step

Low–Medium

Responsiveness / submission package

Narrative acknowledges many admin requirements

Missing pricing/SF1449 completion, missing 3-file organization evidence, missing attachments (licenses, CEP confirmation), missing amendments acknowledgment (if any)

High

Mandatory certifications

Includes VAAR 852.219-75 certification text

Certification left with placeholders and unsigned

Critical

Clause-driven reps/certs

General commitment to comply with security prohibitions

No explicit 52.240-90 representations/disclosures; no 52.222-90 DEI compliance statement; missing some VAAR 852.204-72 detailed procedures

Medium–High

Billing alignment

Acknowledges Tungsten and monthly invoicing generally

Potential inconsistency: monitoring billed quarterly vs monthly invoicing instruction; needs CLIN-specific invoicing plan

Medium

Comply with VAAR 852.204-72 Personnel Vetting and Credentialing; background investigations as required; remove unfit personnel immediately

VAAR 852.204-72; SOW background section

Commits to comply with VAAR 852.204-72; remove unsuitable personnel; contractor bears background costs

Covered

—

PIV/ID card requirements; display ID; lost/stolen reporting; quarterly PIV status report to PIV Sponsor (if applicable)

VAAR 852.204-72(e)-(g)

States Contractor ID badges from VA Police and badge display; does not address lost/stolen reporting or quarterly PIV status reports

Partially Covered

If PIV cards are required (vs local contractor badge), missing process could create compliance issue.

English language requirement

SOW 7(c)

Not addressed

Gap

Add explicit affirmation that all personnel read/write/speak English.

Do not employ persons identified as threats

SOW 9(a)

States will remove individuals found unsuitable/unfit; does not explicitly mirror 'potential threat' prohibition

Partially Covered

Add explicit compliance statement.

Provide Program Manager; designate in writing to CO; include contact details

SOW 8

States will designate Program Manager and backup contact; does not provide the required filled-in fields (name/phone/email/address)

Gap

Solicitation includes a Program Manager information block; omission may be treated as missing required info.

Must be certified SDVOSB listed in SBA certification database at time of offer and award

VAAR 852.219-73

States certified SDVOSB and listed in SBA database

Covered

Include SBA certification screenshot/printout in offer package for responsiveness.

LOS: Services—do not pay >50% to non-similarly situated firms; similarly situated SDVOSB definition applies

VAAR 852.219-73(d); 852.219-75(a)(1)(i)

Narrative commits to LOS and explains similarly situated concept

Covered

—

852.219-75 certification must be completed, signed, returned with offer; failure precludes award

VAAR 852.219-75(d) + Addendum 52.212-1 notice

Includes certification section but leaves offeror legal name/signee/signature/date as placeholders

Gap

High exclusion risk: certification is incomplete/unsigned in current draft.

Prime must do 50% of work (as stated in SOW)

SOW A.3

States will comply with LOS and perform at least 50% of work

Covered

—

R-01

Offer rejected/excluded at preliminary review as non-responsive

Missing SF1449 Section B pricing and required completed blocks; missing 3-file submission structure

High

High

Critical

Submit complete SF1449 with all required blocks and Section B pricing; follow the 3-file structure exactly and label per instructions.

R-02

Ineligible for award due to missing signed VAAR 852.219-75 certification

Certification in proposal contains placeholders and no signature/date

High

High

Critical

Complete, sign, and date the 852.219-75 certification; ensure legal name/address match SAM/UEI and SF1449.

R-03

Failure to meet special standards of responsibility

No attached CEP 10091 confirmation email; no attached license/cert proof; missing references

Medium

High

High

Attach CEP confirmation email, C-10/C-16, Reg4 cert/account proof, and experience certifications + reference list with phone numbers.

R-04

Contract performance noncompliance with 52.240-91 reporting/review requirements

No explicit procedure for quarterly SAM FASCSA review and 72-hour reporting

Medium

High

High

Add supply-chain compliance SOP: quarterly SAM checks, responsible role, and 72-hour CO notification template/process.

R-05

Billing dispute / payment delay

Ambiguity between monthly invoicing requirement and quarterly monitoring billing in SOW

Medium

Medium

Medium

Provide CLIN-by-CLIN invoicing plan: monthly for inspection/testing and dialer programming/service; quarterly in arrears for monitoring CLIN if required.

R-06

Background/PIV administration noncompliance if VA requires PIV cards

Proposal does not address lost/stolen reporting, quarterly PIV status report, or surrender procedures

Low–Medium

Medium

Medium

Add a VAAR 852.204-72 compliance subsection covering PIV lifecycle, incident reporting within required timeframes, and quarterly status reporting.

R-07

Clause compliance challenge (DEI clause)

No explicit 52.222-90 compliance and flowdown statement

Low–Medium

Medium

Medium

Add written acknowledgment of 52.222-90 obligations, reporting, records access, and subcontract flowdown.

Provide a solicitation compliance matrix mapping each SOW/Clause requirement to proposal section and attached evidence

input_proposal.docx

SOW + Addendum 52.212-1 (preliminary review) + responsibility standards

Reduces evaluator effort; lowers non-responsiveness risk.

Submit offer in exactly three files: (1) SF1449 + Section B pricing + amendments ack; (2) CEP 10091 confirmation email; (3) licenses/certs/Reg4 account proof + experience references

input_proposal.docx (submission package)

Addendum 52.212-1 Content Organization

Prevents exclusion for packaging/responsiveness.

Complete all SF1449 required blocks (12, 17a w/UEI, 30a-30c) and include unit/CLIN pricing for 0001–0005 and option CLINs as applicable

input_proposal.docx (File #1)

Addendum 52.212-1 File #1; Section B schedule

Meets minimum offer content and enables price evaluation.

Finalize VAAR 852.219-75 Certificate of Compliance: insert legal name, signatory name/title, signature, date, company address (no placeholders)

input_proposal.docx

VAAR 852.219-75(d) (mandatory, preclusive)

Eliminates critical eligibility defect.

Attach objective proof of: C-10/C-16 licenses; Reg4 certification; active Reg4 account; Siemens/Notifier/Edwards certifications; and reference table with phone numbers

input_proposal.docx (File #3)

SOW A.1–A.2; special standards of responsibility

Supports responsibility determination and technical credibility.

Add explicit clause compliance statements for: FAR 52.240-90 representations (or confirm completed in SAM and state whether any disclosures apply); FAR 52.222-90; and quarterly FASCSA SAM review + 72-hour reporting under 52.240-91

input_proposal.docx

Sections C.4, C.6, E.5; clause compliance expectations

Reduces legal/compliance ambiguity and performance risk.

Clarify invoicing approach CLIN-by-CLIN, reconciling monthly invoicing requirement with quarterly monitoring billing in SOW

input_proposal.docx

B.1 invoices monthly; SOW B.7 monitoring billed quarterly

Avoids payment delays and disputes.

Add a transition step to review/verify previous inspection reports and incorporate findings into initial survey baseline

input_proposal.docx

SOW requirement to verify previous inspection reports

Improves continuity and audit readiness.

Provide Program Manager details (name, phone, email) and confirm authority; include backup contact

input_proposal.docx

SOW 8 Program Manager block

Meets SOW admin requirement; improves coordination.

Add explicit statements for English-language capability and compliance with 'do not employ potential threats' requirement

input_proposal.docx

SOW 7(c) and 9(a)

Closes minor but reviewable compliance gaps.