COVID-19 actually helped small businesses do business

Due to the pandemic, the federal government has expanded remote network access to assist a dispersed workforce. This in turn has motivated reforms to the procurement system.

According to Roya Konzman, acting division director for solutions development at General Services Administration’s Federal Acquisition Service (FAS), “suddenly there was a need for new hardware, software and network access security, so we advised our Small Business Administration, Department of Veteran Affairs and Social Security Administration on their procurement strategies. GSA empowered its contracting officers to expand its rated orders authority. These orders are issued in accordance with the defense priorities and allocation system, and rated orders applied to IT capabilities included teleworking and health care solutions such as VPN accounts, virtual desktop infrastructure solutions, laptops, and mobile devices, and also covered personal protective equipment such as medical products hand sanitizers and disposable gloves.” (GovernmentCIO Media & Research April 6, 2021)

A national emergency allows the use of rated order authority. It authorizes GSA to prioritize a solicitation on behalf of an agency to buy goods and services. If a contractor receives a rated order, the contractor must prioritize that order ahead of other orders in the queue. (ibid)

There were so many rated orders issued to large contractors that individual suppliers often had a hard time meeting demands within the allotted timeframe. The result was federal agencies looked to enlarge their contracting base to include specialized smaller and mid-sized contractors. (ibid)

Because smaller firms do not have the “red tape’ that larger firms have, they can often change directions quickly. This makes smaller firms extremely valuable during times of national crisis. (ibid)

The federal government invested in video conferencing software and remote connectivity during the pandemic. This affords vendors the opportunity to demonstrate their products to various procurement offices. Additionally, agencies can quickly evaluate a large range of potential contractors. Which helps potential contractors who might have otherwise been overshadowed by larger vendors with preexisting relationships. (ibid)

Do you have a specialized product that the federal government needs? Give us a call.

 

Relax a Little – Expiring SAM Deadline Extended

GSA just announced a 180-day extension for organizations with expiring SAM website registrations. Those with registrations expiring between April 1 and September 30, 2021, will automatically be granted an extension. The extension is an effort to alleviate some of the burden during the implementation of the American Rescue Plan Act. (GSA Interact March 29, 2021)

GSA will send an email from samadmin@sam.gov with the subject line “180-Day SAM.gov Extension Granted for [Entity Name/DUNS/CAGE]” to those affected. The extension will not affect first-time registrants. The updated records will be stored within entity management extracts in SAM.gov and available through web services after the records are extended. (ibid)

Need help with your registration? Give us a call.

CTA and Small Businesses

In January, Congress enacted the 2021 National Defense Authorization Act. It includes amendments to the U.S. Anti-Money Laundering Act, the most noteworthy of which is the Corporate Transparency Act (CTA). (JDSupra, March 22, 2021)

The most significant elements of the CTA to know now:

  • CTA legislation requires “beneficial” business owners to report specific information to the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN). A beneficial owner directly or indirectly controls at least 25 percent of the company. Beneficial owners must report their full name, date of birth, current address, and unique identification number. This information will help  prevent the formation of shell companies and money laundering as well as terrorist organization funding.
  • Unless exempt, all privately held businesses in the U.S. are subject to the CTA reporting requirements.
  • CTA becomes effective 1 January 2022. Businesses formed after that time must submit reports within two years.  All business changes are required to be reported within one year.
  • Businesses should add beneficial owner information collection into their operations especially when there are multiple qualifying beneficial owners, as reporting/update deadlines can be cumbersome.
  • Failure to report or update beneficial owner information may include civil penalties up to $500 per day until the violation is corrected as well as criminal fines up to $10,000 and imprisonment for up to two years. (ibid)

The good news is that business entities have almost a full year to get their CTA reporting controls in place, to meet the 1 January 2022 effective date.

Have some CTA regulation reporting questions? Give us a call.

 

FY 2021 SubK Reporting Deadline Extended

The Small Business Administration (SBA) is extending the period for subcontract reporting for fiscal year 2021. The extension allows Federal Contractors (FCs) extra time to correct any issues experienced during the pandemic as well as Federal Agencies (FAs) extra time to review the reports. This will be the final Subcontract Reporting extension. The timeframe for FCs to revise rejected reports is not extended and remains unchanged. (Small Business Administration Notification March 5, 2021)

Extensions provided by the SBA include:

  • 15 days for FC’s report submission due dates and for  the FA’s review periods for the FY 2021 ISRs and SSRs
  • 45 days after the end of the reporting period for FCs to submit their ISR and SSR and 45 days after contract completion if applicable
  • 75 days from the reports’ ending dates for FAs to acknowledge receipt or reject the initial reports
  • 30 days after receipt of a rejection notice, per FAR § 52.219-9(l), for FCs to revise rejected reports
  • 30 days after submittal for FAs to review revised reports

The subcontract report extensions are effective immediately. This pdf contains the formal notice SBA provided for the extension notification. (ibid)

Have questions concerning your ISR or SSR or a rejected report notice? Give us a call.