HHS Did What?

The Department of Health and Human Services Program Support Center (PSC) has decided to end assisted acquisition services. Some agencies under the PSC umbrella include: the Office of Personnel Management, the Office of Special counsel, the Environmental Protection Agency, and the Defense Department (DoD).  (DoD accounts for roughly $1 billion of the $1.4 billion total contract amount under the PSC.) (Federal News Network, July 22, 2019)

It appears HHS stopped offering assisted acquisition services in mid June, just as agencies are preparing for fourth quarter acquisitions. This likely includes the $150 million multiple-award contract PSC was about to award for EPA along with a number of “in-process” contracts for DoD. Additionally, any award for the prior four years must be moved to other agencies or absorbed by the “home” agency by September 20, 2020. (ibid)

So why exactly did HHS decide to stop its assisted acquisition services? In a memo to the civilian agency customers, they said they do not have the internal controls, policies, or procedures necessary. DoD customers received a comparable memo. (ibid)

Why now? Possibly due to the manner in which PSC has handled classified information for DoD and other agencies’ procurements through the self-certification process. The self-certification process is achieved through the DD-254 form. However, a recent audit found that PSC does not actually perform classified work. (ibid)

Unfortunately, this abrupt change is putting a burden on many agencies. Since the decision was made and will affect the fourth-quarter spending, agencies must now scramble to get other assisted acquisition service provider help. The decision also affects vendors, who spend time and money to bid on solicitations that must restart. And the question remains: will vendors lose work from existing contract awards that they bid on and won?

Roughly one-third of all federal spending occurs in the fourth quarter, with one-quarter of the spending in September. Administrators plan to meet with member companies, DoD ,and the Office of Federal Procurement Policy to arrive at  a game plan going forward. (Federal News Network, July 22, 2019)

Will this affect a bid you are working on or a recent contract award? If so, give us a call.

FAR Changes

With the end of the Fiscal Year looming, the push is on to exhaust agency budgets. In an effort to make acquisitions move through the process more quickly and smoothly, DOD, GSA, and NASA have issued an amendment to the Federal Acquisition Regulation (FAR). The amendment fine-tunes the  FAR and eliminates a step in the acquisition process. (Fedscoop, July 15, 2019)

Per the FAR, agencies were required to justify the best procurement approach when using GSA’s IT Schedule 70, Governmentwide Acquisition Contracts, or assisted acquisition solutions. As of June 5, the new FAR amendment allows agencies to skip that step. Agencies are now able to quickly find GSA IT category contracts and acquisition solutions. (ibid)

According to Bill Zielinski, assistant commissioner of GSA’s Federal Acquisition services office, agencies “can now identify and quickly use GSA IT Category contracts and acquisition solutions, especially as they embark on their end-of-year IT spending and acquisition efforts.” Zielinski feels the new change to the FAR reduces the administrative burden for agencies procuring through GSA’s IT Schedule 70 or through GWACs such as 8(a) STARS 2 and Alliant 2, as well as through assisted acquisition programs. (Federal Computer Week, July 15, 2019)

Curious about the new FAR language and how it affects your GSA schedule? Give us a call and we can review it with you.

 

 

DUNS is done!

For roughly 57 years, DUNS numbers, created by Dun & Bradstreet, have been the official entity verification for government contractors and private industry.  It was indexed in the Federal Acquisition Regulation (FAR) in 1998. GSA, the administrator of the program, issued an RFP in 2019, to replace DUNS. Ernst & Young was awarded the new contract, this past March. (Nextgov, July 2019)

What does this all mean? For starters, Ernst & Young will be responsible for administering a new “Unique Entity ID” as well as managing the transition from DUNS. Every organization, including vendors, grantees, and coops doing business with federal agencies will have a new, 12 character identifier, 3 characters longer than the current DUNS number. The Unique Entity ID  is a mix of numbers and letters following a specific set pattern.

A new process is also effective with the updated verification number. Organizations will request a Unique Entity ID when registering with SAM.gov, instead of  applying through a vendor such as Dun & Bradstreet.  To assist with the transition, GSA has released the Unique Entity ID Standard, set up a virtual meeting for July 25, and created a webpage dedicated to the transition for those who would like to know more. (ibid)

The Unique Entity ID is structured to avoid confusion with the old numbers, tax ID numbers and Commercial and Government Entity (CAGE) codes. All systems using the current 9 digit format will require an update to use the longer Unique Entity ID number. (ibid)

Questions about the new Unique Entity ID? Wondering what to do with your old DUNS and how it affects your current contract or one you are bidding on now? Give us a call and we can explain.

 

Scrubbing the FAR

The Federal Register Publications requests comments on the following three proposed Federal Acquisition Regulation (FAR) rules:

  1. FAR Case 2015-002 – the rule proposes to amend the FAR to require electronic submission of DD Form 254, Contract Security Classification Specification. This form is used to communicate security requirements to contractors when the performance of contract requirements requires access to classified information and the form acts to automate processes and workflows. (This form is also used by prime contractors to communicate in the same manner to subcontractors.) Comments should be submitted by September 10, 2019, via the Federal eRulemaking portal. (Acquisition.gov)
  2. FAR Case 2018-007 – the rule proposes to amend the FAR  by revising thresholds subject to inflation adjustments so that the periodic inflation adjustments will apply to existing contracts and subcontracts that contain the revised clauses. The next rule raising thresholds for inflation is planned to go into effect, October 2020. Comments are due by August 23rd, via the Federal eRulemaking portal. (Acquisition.gov)
  3. FAR Case 2018-003 – the rule proposed by NASA, GSA, and DOD is to amend the FAR to implement section 1614 of the National Defense Authorization Act for the Fiscal year 2014 and regulatory changes made by the Small Business Administration (SBA). (Section 1614 addresses credit for lower-tier small business subcontracting.) (ibid) 

Additionally, the following are up for review.

  • Section 1614 of the NDAA for FY 2014 amended the Small Business Act when a prime contractor has an individual subcontracting plan for a contract with a single executive agency, the prime contractor receives credit towards its subcontracting goals for awards made to small business concerns at any tier by subcontractors with individual subcontracting plans. Additionally,  section 1614 provides new assurances for offerors relating to activities to be performed by the contractor to monitor the performance of subcontractors subcontracting plans, and by subcontractors to monitor the performance of their subcontractors subcontracting plans. Section 1614 requires the contractor to demonstrate procedures established to ensure subcontractors at all tiers comply with their subcontracting plans. Section 1614 also revised the definition of “subcontract” in the Small Business Act. (Acquisition.gov)
  • Per SBA’s final rule, the prime contractor’s performance under an individual subcontracting plan will be evaluated based on its combined performance under the first-tier and lower-tier goals. Additionally, the final rule implements the statutory requirements related to the new assurances and written statement to be included in subcontracting plans. Comments are due by August 26th via the Federal eRulemaking portal. (regulations.gov)

Working through how these FAR changes will affect your current contract, or future bidding/contracts? Give us a call and we can explain.

GSAmazon

GSA recently asked for feedback on proposed requirements for the upcoming e-commerce portals program. (Fedscoop, July 2, 2019)

The 2018 National Defense Authorization Act requires GSA put into place a multiple-award proof of concept site similar to those of Amazon and other large online commerce sites. This will update the way agencies purchase products outside of existing contracts. (ibid)

An estimated $6 billion is spent on open-market purchases through government-issued credit cards. The e-commerce portals program pilot will launch with hand-picked agencies and a spending limit of $10,000 on any one order. GSA is asking Congress to raise the threshold to $25,000 for the five-year pilot to better evaluate the program. (ibid)

“During the initial proof of concept, GSA will encourage robust competition through the implementation of multiple e-marketplace platforms,” said a deputy assistant commissioner at the Federal Acquisition Service within GSA. “We are looking to leverage business-to-business terms whenever practicable, to allow for streamlined buying while obtaining a more transparent and centralized view of the type of government-wide spend.” (ibid)

The goal of the Commercial Platforms Program is to start small and refine. The Commercial Platforms Initiative is just one of four Federal Marketplace Strategy projects. The draft solicitation was issued on July 2nd and is open for public comment for 30 days. (GSA interact July 2, 2019)

Interested in how you might fit into the e-commerce portals program? Give us a call.