This response is based on the information provided.  We suggest you discuss with your contracting team, program manager and/or legal department as appropriate.

This is not a compliance issue.  This is a judgement based on what makes sense for your particular acquisition.

Points to consider as you work to create a performance based solicitation:

 - Be clear the government is looking for results, not body count and performance will be measured on outcomes not attendance.

 - Providing historical data as guidance, not direction is useful

 - Consider having the offerors identify key positions as opposed to being mandated by the program office

You should expect the contractor to identify how it intends to accomplish the work and your solicitation should be equally clear in stating success will be measured by results; list/state expected results as applicable.