CTA eligibility
Started by obinnae · Sep 7, 2021 · 8 replies
- oOriginal post
obinnae
Sep 7, 2021 · 4y ago
I'm pretty sure I know the answer to this but cannot find any specific verbiage:
A solicitation is released via Schedule 70 HACS SIN. If I form a CTA, must the CTA lead hold the HACS SIN? Or, can either member of the CTA hold the SIN so long as the lead has a GSA Schedule?
So would the following arrangement be legal?: CTA lead - holds schedule 70 only. CTA member - holds the HACS SIN.
Any guidance?
Thanks!
- C
C Culham
Sep 7, 2021 · 4y ago
Not saying this answers your question but did you go here?
- o
obinnae
Sep 7, 2021 · 4y ago
I did. It does not go down to the SIN level, unfortunately.
C Culham said:
Not saying this answers your question but did you go here?
- C
C Culham
Sep 7, 2021 · 4y ago
obinnae said:
CTA lead hold the HACS SIN? Or, can either member of the CTA hold the SIN so long as the lead has a GSA Schedule?
To hold a SIN must you not hold the FSS contract? Per the reference I provided it seems the only level required is to hold a FSS contract not the SIN. I key in on this - " Under Schedule CTAs, contractors complement each other and it allows teams to compete for orders for which they may not qualify independently."
- o
obinnae
Sep 7, 2021 · 4y ago
C Culham said:
To hold a SIN must you not hold the FSS contract? Per the reference I provided it seems the only level required is to hold a FSS contract not the SIN. I key in on this - " Under Schedule CTAs, contractors complement each other and it allows teams to compete for orders for which they may not qualify independently."
Well yes, but it's not that explicit and that's my confusion. There are a TON of SINS. It doesn't make much sense to me that I could form a CTA based on my holding an FSS and prime a contract for a SIN I have a zero experience in?
- j
joel hoffman
Sep 7, 2021 · 4y ago
That’s precisely why teaming arrangements are allowed, isn’t it?
- c
contractor100
Sep 7, 2021 · 4y ago
Each member of the CTA is technically awarded the GSA contract. You are saying it's okay to award a contract to someone that hasn't been awarded the SIN?
- G
General.Zhukov
Sep 7, 2021 · 4y ago
See Veterans Healthcare Supply Solutions, Inc. B-409888. Quote, from GSA: "If the procurement at issue is for a single SIN, then it would stand that both/all members of a CTA would need to have the particular SIN on their respective FSS contract."
My very unofficial understanding of this protest and how CTA's work is:
Despite the quote, my position is that a CTA member who does not hold the referenced SIN isn't necessarily ineligible. The CTA's proposal would need to demonstrate how the CTA member helps provide the solution. Like, for a given HACS need, I could see how a solution may involve closely-related SINs (like CDM or PKI) and have a CTA member who has those SINs, but not the cybersecurity. In contrast, I doubt a CTA member who has a unrelated IT SIN (say, A/V equipment) could legit join a CTA for cybersecurity.
This protest is from 2014, and GSA has changed how the schedules work since then, so this reasoning may not be fully valid in 2021.
The solicitation matters, since it can customize what types of CTAs can respond. For example, an RFQ may state that all CTA members must hold a specific SIN.
There are lots of protests about CTAs.
- o
obinnae
Sep 7, 2021 · 4y ago
General.Zhukov said:
See Veterans Healthcare Supply Solutions, Inc. B-409888. Quote, from GSA: "If the procurement at issue is for a single SIN, then it would stand that both/all members of a CTA would need to have the particular SIN on their respective FSS contract."
My very unofficial understanding of this protest and how CTA's work is:
Despite the quote, my position is that a CTA member who does not hold the referenced SIN isn't necessarily ineligible. The CTA's proposal would need to demonstrate how the CTA member helps provide the solution. Like, for a given HACS need, I could see how a solution may involve closely-related SINs (like CDM or PKI) and have a CTA member who has those SINs, but not the cybersecurity. In contrast, I doubt a CTA member who has a unrelated IT SIN (say, A/V equipment) could legit join a CTA for cybersecurity.
This protest is from 2014, and GSA has changed how the schedules work a lot since then, so this reasoning may not be fully valid in 2021.
The solicitation matters a lot, since it can customize what types of CTAs can respond. For example, an RFQ may state that all CTA members must hold a specific SIN.
There are lots of protests about CTAs.
Very helpful. Thank you!