The Department of Homeland Security (DHS) is deep in the acquisition process for a follow-on to the Programmatics, Administration, Clerical, and Technical Services (PACTS) contract. This one will be called PACTS III. DHS started the ball rolling on PACTS III back in August of 2022 with a Notice of Intent to Recompete and has provided updates several times since. The latest update provided answers to questions from the Industry Day held on November 9th of last year.

The last major release of a PACTS III draft RFP occurred in late October, with substantial changes from the prior release. These changes include:

  • Notification that the Government evaluation will be based upon the Functional Category, socioeconomic track, and type of Offeror
  • Relevant projects may come from any type of business arrangement (Prime, JV, Small Business Teaming arrangement, etc.)
  • Forty percent of all projects verified must have been performed by a business entity of the same socioeconomic status associated with the track the Offeror is proposing
  • Additional points will be awarded for partnership arrangements that show proven experience for managing teams of the same size or larger on other projects.

The final PACTS III RFP will be three different solicitations, one for each Functional Category. The last draft represented Category 1, but the Government has stated that the other two will be very similar. The final RFP is expected in early February.


The gist of the PACTS III procurement is to provide non-IT support services to a number of areas including consulting, clerical, personnel, physical distribution, billing, reporting, operations, financial planning, stenotype, and record keeping. The three NAICS codes that would look to be in play are 561110 Office Administrative Services; 541611 Administrative Management and General Management Consulting Services; and 541330 Engineering Services.

Small Business size limits for the three NAICS codes are as follows:

  1. NAICS 561110 – $12.5M
  2. NAICS 541611 – $24.5M
  3. NAICS 541330 – $25.5M

Both of the first two iterations of the contract have ceilings of $1.5 billion but only spent that in the aggregate through the current year for the 14-year period of performance. PACTS III has a current estimated ceiling of $8.4 billion which is considerably larger than the $1.1 billion through the eight years of the current contract. All the current contracts are set to expire at the end of February 2025; so expect an award date somewhere in very early FY25 to allow for transition.

There will be a lot of detail required for this submission which will result in separate IDIQ contracts under each of the following small business set aside programs:

  • WOSB
  • HUBZone
  • 8(a)

The current PACTS III draft RFP is somewhat confusing as to the actual number of contracts to be awarded. It states, “The DHS anticipates making an estimated eight (8) contract awards within each FC and small business socioeconomic track to ensure that beneficial competition occurs at the task order level while maximizing the effectiveness and efficiency of PACTS III. Of the eight (8) contract awards, the Government estimates two (2) will be provided to each type of Offeror as defined in paragraph 1.3 below for each of the four (4) tracks within each of the three (3) individual functional categories.” We can’t glean where the number “8” comes from based upon this wording, so expect some clarification to be made in the final RFP.

Nearly 350 questions have been asked and answered since the November 9, Industry Day, and a number of the answers indicate that a significant number of issues will be “resolved” in the final RFP. Expect at least a 60-day response period and potentially longer with extensions due to unresolved questions and new issues being raised. Earlier, we noted a potential award date of early in FY25. Any extensions to the process will no doubt impact this data and may push the Government to extend the current contracts.

Based upon the current draft RFP, THERE ARE NO PAGE RESTRICTIONS for the proposal. This is both good news and bad news. The temptation will be to wax eloquent with your documentation and descriptions; but well-written succinct writing will be critical to winning. Getting a technical writing team involved to track your relevant projects will be nearly mandatory, given the number of competitors anticipated and the fact that there doesn’t appear to be any restriction on the number of projects that may be submitted as “relevant.” In fact, the draft RFP itself references as an example, a submission containing a total of “100 projects.”

Here’s a brief look at the Volume requirements:

  • Volume I – Executive Summary. While this is called an “Executive Summary,” it’s not what we would call traditional. A mandatory attachment along with some additional information is required but nothing like what we normally consider an ES.
  • Volume II – Technical. This will be the heart of your proposal, which will include your self-scoring worksheet along with all the documentation required to support your scores. Per the draft, “There is no limitation to the number of qualifying projects an Offeror can claim under the Experience and Past Performance subfactor for each Functional Category.” Also, there is further amplification coming from the Government with regard to minimum project size. While stated as greater than $1M, it appears from the Q&A that this could change. Included within this volume is:
    • Past Performance
    • Adequate Accounting System
    • Facility Clearance
  • Volume III – Price. This will include the labor rates for the approximately 85 labor categories.

PACTS III Challenges:

Because of the lack of limitation as to the number of relevant projects that can be submitted, this proposal response will be an exercise in marshalling forces and designating teams to work on the required documentation submittals to ensure that all the nitty gritty details are covered. You’ll have to choose a reasonable number of projects to present. For very small businesses with limited experience, this may include your entire portfolio of projects. Consider how best to present those projects and whether your organization has the wherewithal to present its best foot forward. For larger small businesses and those that have been in business for more than a few years, you may have considerably more depending upon what is established as the final minimum project dollar amount. Your challenge will be to coordinate a number of teams putting together your portfolio of documentation.

For those of you who submitted bids under Polaris and OASIS+, it appears that this effort may well be an order of magnitude larger than either of those. Do you have the resources to support an effort of this size while you may also be pursuing other contracts with current clients with shorter turnaround times?

If you face any challenges, please understand that OCI is ready to partner with you in ensuring your organization best represents itself for this effort through proposal management, coordination, technical writing, editing, and price-to-win analysis. We’re only a phone call away. Contact us today to get proposal help.