New SIN for Office Admin Services

Under the new Multiple Award Schedule, GSA is changing the Special Item Numbers (SINs) in the Office Management and Human Capital large categories. GSA’s Northeast and Caribbean Supply and Acquisition Center and the Office of Customer and Stakeholder Engagement (CASE) are adding the new NACIS-based SIN56110 for Office Administrative Services. In addition, GSA is combining the two current SINs for Human Resources Line of Business into SIN 541612LOB. These changes all take effect on 1 July 2020. (GSA Interact June 24, 2020)

SIN 56110 will make it easier for searching and identifying specific support services to meet mission-critical needs. These services include a range of day-to-day activities, such as office administrative support, data entry, payroll administration, recordkeeping, travel preparation, scheduling, meeting management, purchasing supplies, and logistics.

To better meet agency needs, GSA is merging two SINs of the consolidated schedule, into one new SIN. The two SINs 541612OPM and 541612PSSC will be combined into 541612LOB. This new SIN provides technology solutions in support of other SINs in the Human Capital category. This category may include software, technology, systems, and related solutions. To be a function under this SIN, the services and products offered must support one or more of the 15 functions/54 sub-functions in the human capital lifecycle. To obtain a list of theses functions, visit the Human Capital Business Reference Model (HCBRM).

GSA is holding a webinar tomorrow, Friday, 26 June 2020, to review details and answer your questions. The link to join the webinar is https://meet.gsa.gov/r2newsins/. (ibid)

Questions about the Office Management and Human Capital large categories? Give us a call.

CMMC not for COTS

A recent modification to DoD’s website spells out a small but very specific change about the Cybersecurity Maturity Model Certification (CMMC): it’s not applicable to DoD suppliers that only provide commercial-off-the-shelf products. (FedScoop, May 5, 2020)

Originally, DoD and CMMC administrators explained that all contractors and subcontractors must be certified under  CMMC by a third-party assessor. However, a few weeks ago, the Office of the Under Secretary of Defense for Acquisition and Sustainment changed the official website. The revised FAQ section states: “Companies that solely produce Commercial-Off-The-Shelf (COTS) products do not require a CMMC certification.” (ibid)

CMMC is in place to certify contractors have the cybersecurity practices in place to work with controlled unclassified information, the actual products themselves. (ibid)

Wondering if CMMC applies to the products and or services you provide? Give us a call.

GSA, Pandemic Style

GSA is moving quickly to enact several initiatives while responding to the COVID-19 pandemic. Because the current state of emergency necessitates the Federal Acquisition Service to purchase medical supplies and other equipment at a fast clip, Contracting Officers have no choice but to react with a fair amount of speed and flexibility. (Federal News Network, May 1, 2020)

This includes:

  • changing policies for prompt payment and onboarding/offboarding of contractors
  • construction of the new e-commerce marketplace platform, which was paused during the first few weeks of the pandemic, is now moving forward, albeit at a much slower pace
  • monitoring other initiatives possibly impacting by the pandemic, such as Enterprise Infrastructure Solutions (EIS)
  • continuing corrective actions on Alliant 2 revised proposals
  • expanding the small business innovation research (SBIR) program, part three

Some government markets, like travel, have declined; however cleaning products and enhanced screening services have increased exponentially. (ibid)

Any questions about getting your product or service in front of government buyers? Give us a call.

Emergency Rules

Government ontractors and small businesses should be aware of increased opportunities during the current COVID-19 national emergency. The government is permitted, during a national emergency, to set aside solicitations to allow awards “only to offerors residing or doing business primarily in the area affected by …[a] major disaster or emergency.” Contractors can verify if they fall into this category by reviewing Federal Acquisition Regulation 52.226-3(d). (Law360.com, April 13, 2020)

A national emergency declaration allows the government to (restrict) certain solicitations to small businesses in certain areas. These solicitations are either a set-aside or an evaluation preference is given to small businesses. (ibid)

During national emergencies, large contractors should look to team with small businesses, or to current teaming agreements already in place. In addition, contractors who are at the ready to produce/provide goods or services may be called on to contract with agencies to battle COVID-19. (ibid)

Micro purchase thresholds are another acquisition procedure government agencies may use during a national emergency. These allow for a simplified acquisition methodology for specific items or services required under emergency situations, such as the COVID-19 national emergency. (ibid)

State and local governments may also procure under the Stafford Act, wherein state governors request financial relief via federal grants that allow procurement under their own procedures. The Stafford Act authorizes federal contracts for “debris clearance, distribution of supplies, reconstruction, and other major disaster or emergency assistance activities.” In 2006 the Local Community Recovery Act amended the Stafford Act mandating local organizations to be given preference when using full and open competition. The FAR was also amended to align with the Local Community Recovery Act. Under the act, if a contractor does not meet all of the Recovery Act stipulations there are other factors that may be considered. (Contractors may self-certify that they are local.) (ibid)

Other streamlining acquisition procedures are available under federal supply schedule contracts, multi-agency blanket purchase agreements, and multi-agency indefinite-delivery contracts. Additionally, there is an easing of the requirement that a contractor be registered in SAM.gov at the time an offer is submitted to the government. (ibid)

The emergency declaration allows state and local governments to purchase from all GSA schedules. It also encourages accelerated payments to small business contractors.  (ibid)

Additional modified procedures to facilitate swift responses are:

  • Relaxation of qualifications requirements
  • Use of sole-source contracts
  • Use of oral requests for proposals
  • Use of letter contracts
  • Interagency acquisitions
  • Awards to small disadvantaged businesses
  • Retroactive overtime approvals
  • Waivers of bid guarantees when an emergency exists
  • Use of protest overrides where necessary for a contracting process to continue

In order to track procurements related to COVID-19, GSA added a National Interest Action (NIA) code to SAM.gov. To find information on the site, simply type COVID-19 2020 in the search bar. (ibid) Contractors can register with SAM.gov under the disaster response registry, and be sure to monitor the portals most closely aligned to the goods or services you provide.

Have questions about the many opportunities available under the current national emergency? Give us a call.

GSA Allowing Some non-TAA Compliant Products

Demand for essential supplies during the COVID-19 pandemic has escalated to the point that GSA Senior Procurement Executive (SPE) has issued a Class Determination and Findings (D&F) that temporarily allows procurement of non-Trade Agreement Act (TAA) compliant products through the GSA Schedule contracts. Unavailability of the Federal Supply Classes found in GSA’s SPE memo dated 3 April 2020 is cited as the rationale for the change in contractor procedures. (GSA Interact, April 15, 2020)

All MAS contractors with access to products under these FSCs and able to meet the urgent need should submit a stand-alone modification request via eMod. Information and detailed instructions for submitting the modification along with required templates can be found on the GSA.gov, MAS Contractor and Modification Requirements page. (ibid)

The Federal Acquisition Service will email contractors to which the D&F may apply . If you do not receive an email or your authorized negotiator is not up to date, please contact your Procurement Contracting Officer (PCO). A PCO listing may be found by searching your contract number or company name on gsaelibrary.gsa.gov.

Are you able to meet the urgent needs of the government but do not know how to navigate the MAS Contractor and Modification Requirements? Give us a call.