Yes Virginia, There Is a Data Ethics Framework

Earlier this month, GSA was given the opportunity to develop a Data Ethics Framework to assist agencies in making ethical decisions as they acquire, manage, and use data. A completed version of the report is expected by the end of 2020. (GSA Data ethics framework action 14 draft, September 2020)

The Framework incorporates four parts:

  • About the Data Ethics Framework — explains the purpose and audience of the Framework.
  • Data Ethics Defined
  • Data Ethics Tenets — provides seven principles for using data ethically within the federal government.
  • Data Ethics Tenets in Action — details data ethics benefits and demonstrates how the Tenets guide data activities within agencies as well as federally sponsored programs. (ibid)

The Framework originated to guide ethical decision making by federal employees who collect, manage, or use data to support their agency’s mission. It acts as guidance to encourage ethical decision making, but isn’t required. Its audience includes “anyone in the Federal Government who works with or leads work involving data, which includes all employees, contractors, researchers, and other partners who work on behalf of the government.”

According to the Framework, “Data leaders and professionals should adhere to all applicable legal authorities, as ethics are reflected and reinforced in existing laws.” Additionally, “agency leaders are encouraged to maintain up-to-date, comprehensive ethical standards regarding data use and staff are responsible for learning and applying agency guidance. In addition, if a person works in an area with recognized professional ethical codes of conduct, they should be aware of those standards and strive to uphold them.” (ibid)

Have a question about the Framework or the definition of data ethics? Give us a call we can explain.

SubK Silver Lining

The U.S. Small Business Administration (SBA) is extending the time for contractors to file Individual Subcontracting Reports (ISR) by 30 days and Summary Subcontracting Reports (SSR) by 60 days. (Small Business Administration Extension Notice, August 27, 2020)

SBA reasoned that, due to the pandemic and social distancing requirements in a number of states including the District of Columbia, many records remain unattainable. Without proper records, contractors are not able to meet reporting requirements.  New deadlines for ISRs is 30 November 2020 and for SSRs is 30 December 2020. SBA is also extending the deadline to 30 November for vendors who have recently completed contracts or will complete contracts before 30 September. No financial or liability consequences will be imposed on contractors for taking advantage of the updated deadlines.

The extension notice is being sent to those on the SBPAC list as well as all government and business personnel with a valid email in eSRS. (ibid)

Not sure if the extension notice applies to you? Give us a call.

Seeing STARS

The 8(a) STARS II contract has roughly 800 small business contractors that furnish custom IT services-based solutions tailored to meet government agency needs. STARS III contract will soon replace the current STARS II contract, with a higher dollar threshold and customized IT solutions. (Federal Computer Week, August 21, 2020)

Over the life of 8(a) STARS II, GSA has repeatedly raised the ceiling to meet federal agency needs and to support their small business contracting objectives. In April of this year the contract reached a $15 billion ceiling and by the end of July is was at $22 billion. In an effort to meet growing government agency needs, the 8(a) STARS III contract will accommodate more bidders with a $50 billion ceiling. 8(a) STARS III focuses on new technologies as well as meeting the needs of federal agencies outside the continental U.S.

According to Alan Chvotkin, executive vice president and counsel at the Professional Services Counsel, “rules have changed a lot over the years, the current contract vehicle, dating back to 2011 is kind of clunky and not as nimble as newer contracts. The new contract will help GSA fine new technology companies as well as requalify existing companies.” (ibid)

Questions about the 8(a) STARS III contract and if you currently do business under 8(a) STARS II how you will requalify? Give us a call.

One and Done!

Earlier this week, Phase 3 of the Multiple Award Schedule (MAS) Consolidation began. Each contractor with one or more contracts now has its offerings under one contract or unique entity identifier (UEI) number. (GSA Interact, August 3, 2020)

GSA designed Phase 3 to make sure contract numbers remain the same Blanket Purchase Agreements (BPAs) remain in effect. Contractors affected by Phase 3 received emails from the MAS Program Management Office (PMO) with guidance on consolidating their contracts. All contractors should review the contractor checklist & planning spreadsheet for outlining the elements of their contracts as well as planning for consolidation. (ibid)

Also as of this week, contractors that haven’t signed the Mass Mod are no longer visible on GSA eTools. Contracts are not canceled, but contractor information is hidden from view until the Mass Mod is signed. Additionally, all 24 legacy Schedules are no longer visible in eLibrary, eBuy, or on GSA.gov. (All eBuy changes may be viewed on this resource.) (ibid)

If you are a contractor with multiple contracts, consider joining one of the two training opportunities below:

Monday, August 10th (11:00 AM – 12:00 PM ET): Register here. (please select NON-GSA User if from industry)

Wednesday, August 26th (2:00 PM – 3:00 PM ET): Register here. (please select NON-GSA User if from industry)

Training is recorded for those unable to attend the live training. Information will be provided on the MAS Interact page. (GSA Interact, August 3, 2020)

Through the Multiple Award Schedule, GSA has generated long-term government contracts with the commercial sector that provide nearly 10 million supplies and services for government agencies. To that end, the government spends upwards of $30 billion through the GSA schedule. It is crucial if you have a GSA schedule contract that you sign on for the mass modification immediately. (Nextgov,August 3, 2020)

Questions about the MAS consolidation or your current GSA schedule contract? Give us a call.

Practical Applications on the Chinese Tech Ban

On 23 July, the Defense Department released a memo explaining requirements for companies and contractors when the ban of telecommunications equipment made by Huawei and other China-based companies goes into effect. (Federal Computer Week, July 27, 2020)

Beginning 13 August, no contracts will be issued or extended to contractors using technologies or services and equipment made by Hikvision, ZTE or those listed in section 889(a)(1)(B) of the National Defense Authorization Act (NDAA) for Fiscal Year 2019. Any contract, task/delivery order, and off-the-shelf items purchased after 13 August must include language invoking regulation for the ban. Additionally, indefinite delivery contracts are required to be modified. (ibid)

There is a waiver process, however, pursuable by agencies. According to Alan Dhvotkin PSC executive vice president and counsel, the waiver “will most likely begin with issues identified by the telecommunications provider to its federal agency customer. The federal agency then asks for an ODNI review, which will conduct a risk assessment.” A granted waiver lasts two years and may be requested at any time. (Federal Computer Week, July 22, 2020)

Have questions or need a waiver? Give us a call.