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GSA Schedule contract

What Brand is Your Telcom and Video?

Section 889 of the FY 2019 National Defense Authorization Act was passed to fight national security and intellectual property threats to the United States.  The legislation includes two prohibitions Part A and Part B. (GSA Section 889 Industry Focused Flyer, GSA.gov, July 16, 2020)

Part A, which became effective on August 13, 2019 bans telecommunications/video surveillance equipment made by the following companies:

  • Huawei Technologies Company
  • ZTE Corporation
  • Hytera Communications Corporation
  • Hangzhou Hikvision Digital Technology Company
  • Dahua Technology Company

Part A can be found in the Federal Acquisition Regulation (FAR) at FAR subpart 2.1.

Part B, effective 13 August 2020, prohibits the government from contracting with any organization that uses equipment or services of any of the companies listed under Part A. Part B applies, whether or not that usage is in performance of work under a Federal contract. In other words, if you use any of the banned companies in the fulfillment of a  non-government contract, you will be prohibited from working with the government. All contractors must verify whether they do or do not use prohibited telecommunications/video surveillance equipment or services. Part B has been added to the Federal Acquisition Regulation (FAR) at FAR subpart 4.21. (ibid)

GSA recommends companies to complete an in-depth review of all in-house technology to rule out using banned companies in Part A . If prohibited equipment or services are being used, companies that wish to continue doing business with the government must eliminate them. GSA does not take responsibility for changes contractors make, unless done so by a modification to a current contract.

However, two possible waiver procedures with extremely high standards are available. This is to ensure waivers are not used to get “around” the prohibitions.

GSA is modifying all solicitations, Indefinite Delivery Vehicles (IDVs), GWACs, and other IDIQ contracts, to include Section 889 Part B requirements immediately. These requirements will be added to GSA’s existing non-IDV contracts as those contracts have their periods of performance extended.

GSA is hosting the following events so that industry may obtain additional guidance:

  1. The GSA Office of Small Business Utilization webinar on Section 889, July 30, 2020, 2:00 p.m. EST, registration may be found here.
  2. GSA recorded virtual webinar August 12, 2020, at 1:00 p.m. EST, registration forthcoming. This webinar will include leaders from GSA’s business lines explaining how they are implementing Section 889 into their business lines and panelists will answer pre-collected questions. (Questions may be sent to gsaombudsman@gsa.gov to arrive by COB August 5, 2020.) (ibid)

GSA recommends that vendors study the tools and publications to aid their understanding and compliance, as provided in Acquisition.gov.

Not certain if your contract is affected by Section 889 Part B and if so, what you can do? Give us a call.

Time to Sign the Dotted Line

If you are one of the 15 percent of contractors who have yet to accept GSA’s consolidation Mass Modification, do it now. The deadline is 31 July 2020. All contractors failing to accept the Mass Mod will have their offerings removed from GSA’s eTools platform. (Fedscoop July 13, 2020)

Jessica Salmoiraghi, the associate administrator of the Office of Governmentwide Policy, recently said contractors that fail to accept the mass mod are basically losing out on business, while the contractors who have accepted are realizing orders. (ibid)

As GSA moves further into Phase 2 of MAS consolidation, they are automating parts of the contracting process. This includes its Truman bot, designed to automatically review new contractors based on the MAS. The bot is automating the new offer review process by checking the excluded parties list and pre-filling templates. (ibid)

The third and final phase of MAS Consolidation is expected in the second half of 2020.

Need assistance getting your acceptance to GSA’s mass mod completed in the next two weeks? Give us a call.

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.