Dun(s) Dun Dun Dun … No More

After almost 60 years of utilizing a DUNs number, every organization doing business with the government will receive a new identification number. Beginning in December 2020, the number and the process to acquire the Unique Entity Identifier (UEI) will change. The new identifier will be generated through SAM.gov; however, DUNS numbers will be retained for historical purposes and Dunn & Bradstreet open data limitations remain in effect in perpetuity.

GSA is moving to a new, non-proprietary identifier, a 12 character alpha-numeric value, will be assigned by the System for Award Management. The Federal Register announced the new (UEI), including the identifier standards. Additional updates to the UEI can be found here: gsa.gov/entityid. (GSA.gov Unique Entity Identifier Update, September 9, 2019)

As you can imagine, many questions surround the upcoming change, and GSA’s recent online meeting answered some of them. Those that missed the meeting or want to listen again can find the presentation at beta.SAM.gov  and selecting the UEI video link. All questions submitted and answers provided are also available on this downloadable pdf.

The transition phase began in July of 2019, but DUNS will continue as the official identifier until December 2020. During the transition, all existing entity registrations will automatically be assigned a new UEI which will be displayed in SAM.gov and no one will be required to re-enter this data. (ibid)

Thinking this small change can lead to a lot of confusion? Have some questions that didn’t get asked or answered during the GSA public meeting? Give us a call.

Program UnSupport Center

Back in June, the Health and Human Services Department (HHS) announced it would halt assisted acquisition services for non-HHS customers after September 30, 2020. Until the announcement, HHS provided assistance through the Program Support Center (PSC). After the deadline, all 19 agencies (with more than $1.4 billion in contracts per year) who had contracts administered by HHS will have to look elsewhere or figure out how to administer the contracts themselves. (Government Executive, September 13, 2019)

PSC lacks the procedures, policies, and internal controls to work with agencies outside of HHS. In addition, questions have been raised as to whether the PSC is actually legally authorized to administer contracts for agencies outside of HHS. (ibid)

Many questions remain unanswered, such as the fate of bids in the process of evaluation. Unfortunately, the PSC is not communicating with customers at this time, according to Federal News Network. This is surprising, as the Office of the Assistant Secretary of Administration focused on the need for “continuous communication” in customer service. (ibid)

So where will all of these contracts be administered? An EPA spokesperson said EPA contracts will either placed on new or existing EPA contract vehicles or handled through interagency agreements with other federal agencies. The Office of Special Counsel is partnering with Merit Systems Protection Board to process a number of mission-critical procurements. In 2020 GSA is assisting OSC with their procurement requirements. (ibid)

If you have questions about how this affects a current bid or your current HHS-administered contract, give us a call.

Show Me the Money! All the Money!

End of fiscal year 2019 spending will likely exceed that of 2018. So much so that hours are being extended for the largest Government-Wide Acquisition Contracts. (Federal Computer Week, August 30, 2019)

A few contributing factors precipitating  the uptick in spending:

  • The credit card threshold for micro-purchases increased from $3,500 to $10,000
  • A stable budget allows agencies the ideal scenario to plan and use their funding.
  • The last day of the fiscal year falls on a weekday this year. (ibid)

For instance, the National Institutes of Health Information Technology Acquisition and Assessment Center (NITAAC) expect a very busy September. They have been designated “best in class” across all three of their GWACs, which will likely bring in additional work. as extended hours in September as does the Solutions for Enterprise-Wide Procurement (SEWP). According to Joanne Woytek, manager for NASA’s SEWP,  processing systems have been updated to a High Availability System. The update took place earlier in the year and additional staff was added overall not just to respond to the additional spending in September.

NITAAC has improved its e-GOS next-generation customer ordering portal, which mirrors commercial online shopping and makes shopping easier for contracting officers. Item comparisons and photos will be part of the buying experience. The changes will be a key factor in streamlining the purchasing process, thus making ordering easier and faster. (ibid)

Not to be outdone, GSA also expects September to be the busiest month of the year for their Government-Wide Acquisition Contracts. (ibid)

Questions about the September buying frenzy and how you can take advantage? Give us a call.

Time to Uncover Some Chinese Equipment

Recently, GSA sent a letter to contractors explaining the new FAR interim rule regarding supply chain security, which went into effect last month. The rule prohibits federal agencies from procuring, obtaining, extending, or renewing a contract to procure or obtain “any equipment, system, or service that uses covered telecommunications equipment or services  as a substantial or essential component of any system or as critical technology as part of any system.” (Acquisition.gov)

Covered equipment encompasses telecommunications and video surveillance products and services by Hauwei Technologies Company, ZTE Corporation, Hytera Communications Corporation, Hikvision Digital Technology Company, or Hahua Technology Company, or any company that the head of a relevant federal agency reasonably believes is controlled by the government of the Peoples Republic of China.

The interim rule:

  • Prohibits contractors from providing covered telecommunications services/equipment unless an exception or waiver is granted
  • Mandates every offeror represent whether it will provide covered telecommunications equipment/services as part of its offer, and if that is the case, the offeror must provide details about the covered equipment or services
  • Requires contractors to report any covered equipment/services throughout the life of the contract. (ibid)

At the same time, the FAR interim rule went into effect, GSA issued a class deviation. This essentially takes a risk-based approach to the new FAR interim rule by limiting the representation requirement for GSA funded orders to the indefinite-delivery contract level. The deviation necessitates the following:

  • At all times requires an order-level representation for acquisition vehicles that carry a “high risk” of including covered telecommunications equipment or services.
  • Must have an order-level representation for all orders that could include information technology or communications technology under all GSA acquisitions.
  • The creation of a GSA Acquisition Regulation (GSAR) representation clause, requiring the GSAR and FAR reporting clauses in all new and ongoing GSA contracts.
  • Initiates GSA specific implementation targets for modification of existing contracts.
  • Simplifies the application of Section 889 of the NDAA to other GSA program areas. (ibid)

The interim rule affects ALL contractors. As a contractor, you are responsible for determining whether covered telecommunications equipment/services will be provided under both new and existing contracts and orders.

Below is some fundamental information to help you prepare as GSA puts into place the interim rule and class deviation:

  • FAS contracting activity will issue a mod requiring you to respond to incorporate FAR clause 52.204-25 and GSAR clause 552.204-70.
  • Your mod response must delineate if you will or will not provide covered telecommunications equipment/services in the performance of any contract, subcontract, order, or any other contractual instrument.
  • The substance of FAR clause 52.204-25 must be inserted into all subcontracts.
  • You must report any covered telecommunication equipment or services you discover during the course of contract performance.
  • For new GSA solicitations, you are required to represent at the contract level if you will or won’t provide covered telecommunications equipment/services to the Government in the performance of a contract or subcontract.
  • Contract level solicitations will include FAR provision 52.204-24, clause 52.204-25and GSAR clause 552.204-70.
  • In responses to solicitations and orders under indefinite-delivery contracts, representation of FAR 52.204-24 is required when there is a high risk of inclusion of covered telecommunications equipment/services. (ibid)

Wondering how all this might affect your current contract or upcoming bid? Give us a call.