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The record shows that the agency evaluated cost proposals for reasonableness, realism, and completeness before making adjustments to certain costs as part of its MPC analysis. With respect to cost reasonableness, the agency conducted a standard deviation analysis, first based on the average total cost of the four submitted proposals, and then additionally included the IGCE as part of the analysis.
AR, Tab 49, Cost Evaluation, at The agency also found all proposals to be complete.
The agency also conducted a cost realism analysis, comparing cost elements of each proposal. The record reflects that the agency adjusted offeror rates where it was able to obtain DCAA verification of those rates, but did not otherwise adjust any other direct labor rates or associated indirect costs.
The record does not show that the agency made any other adjustments to direct labor rates or associated indirect rates for offerors where rate verification was not obtained from DCAA. As an initial matter, the use of historical direct labor rates verified by DCAA as part of a cost realism evaluation is generally unobjectionable.
The record does not reflect any analysis of non-DCAA verified rates, even though the agency had available to it rates proposed by other offerors, including the incumbent, for comparison.
Therefore, we sustain the protest on this basis. Agencies are required to perform such an analysis when awarding cost-reimbursement contracts to determine the probable cost of performance for each offeror. Agencies are given broad discretion to make cost realism evaluations.
The agency issued multiple cost evaluation notices to Zantech, including evaluation notices requesting an explanation of the selection of specific labor categories and the percentiles chosen for each category.
Zantech responded to the evaluation notices by providing additional rationale to support the rates. Zantech explained that this approach enabled the firm to maintain low costs yet hire highly-qualified individuals where needed.
Zantech also provided a screenshot from salary.
With respect to SSES, the record reflects that in its mission suitability proposal, specifically in its discussion under the staffing element of the management approach subfactor, the firm proposed a reduction of [Work Year Equivalents] WYEs over the life of the contract.
In this section of its proposal, the firm briefly explained as follows: The firm also included a table outlining the staffing levels for each labor category. As noted above, the SEB assigned the proposal a significant weakness under this staffing element of the management approach subfactor.
No additional information was documented in the evaluation report regarding this weakness. SSES challenges the adjustment. Specifically, the protester contends that in making the cost adjustment, NASA failed to take into account numerous innovations and efficiencies that substantiated the proposed WYE reductions.
More specifically, pursuant to the RFP instructions, see RFP atSSES included three pages of substantiating information in the innovations and efficiencies part of its proposal, which was to be assessed under the fourth element of the understanding the requirements UR4 subfactor.
In addition, SSES also included the substantiating information detailing its proposed innovations and efficiencies in its cost proposal.
As explained above, the cost adjustment was made solely because of the significant weakness under the staffing element of the management approach MA2 subfactor. We find this allegation to be meritorious. See RFP at More specifically, SSES documented in detail numerous contract management innovations, technical performance improvements, and staffing strategies in support of its proposed staffing levels.
Indeed, SSES described seven different innovations or efficiencies, with explanations about when the strategy would be implemented, the cost to the government, and the benefits to GRC in terms of staff savings.
For the reasons discussed below, we find no basis to sustain the protest. An agency is not required to conduct an in-depth cost analysis, or to verify each and every item in assessing cost realism; rather, the evaluation requires the exercise of informed judgment by the contracting agency.
Sections in 1 and 2 above are lenghty and available in the linked protest decision. See Protest at Using Thermal energy from 2 wells to heat the Sussex Hospital in New Brunswick.
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