Oh Say Can You See? Focus on the Micro-Purchase Threshold

During a recent industry day, GSA reiterated that the Portals Program will focus on transactions under the Micro-Purchase Threshold. The current draft of the 2019 National Defense Authorization Act grants a GSA request to increase the Micro-Purchase threshold for purchases through approved portals to $25,000. If included  in the final draft, this will make the Portals Program the preferred vehicle for any micro-purchases. The GSA Schedules Program will remain the preferred contracting vehicle for all other commercial item procurements. GSA said this would simplify the acquisition process and address federal buying requirements (such as considering AbilityOne and designated small business contractors for procurement).

On the other hand, not all industry partners are so enthusiastic. Will this create two completely separate market places for the same services and products, at two different price barriers? Some contractors are nervous that the Portal initiative might create a different compliance structure from Multiple Award Contracts,  potentially leaving businesses with difficult decisions. The concern is that the move will create parallel systems of compliance and companies will have to weigh the cost of navigating both.

Roger Waldron, president of Coalition for Government Procurement, has an example. “If there are compliance requirements in one channel and they don’t exist in another channel, do (businesses) stay in the channel where they have compliance requirements and increase costs and lower margins? They are going to be making those kinds of business decisions ultimately.”

In response, GSA officials said they are still weighing how to design the policies for the portals and would be testing the new micropurchase threshold in a proof of concept pilot sometime next year. Jeffrey Koses of the Office of Governmentwide Policy said GSA is “still trying to determine if this is more of an [indefinite delivery/indefinite quantity] type of relationship or is this something else. It’s a fair question. I don’t know if we have all of the answers at this point.”

GSA released two RFIs about the regulations needed- one for suppliers that sell on commercial e-commerce platforms and one for commercial providers. Leave your thoughts there, or in our comments.

Ride the On-Ramp to OASIS

GSA to add On-Ramps to OASIS unrestricted pools

On May 9, GSA announced plans to add vendors to two underused OASIS pools: pool two for financial services, and pool six for aircraft R&D.

OASIS, a set of 10-year government wide multiple-award-contracts, totals $60 billion for knowledge-based services such as management and consulting services. GSA plans to make 15 contract awards for pool two, and two contract awards for pool six. A final RFP should be released by May 31, after which vendors will have 30 days to submit proposals.

Since fiscal year 2015, most contract holders on most pools haven’t won many orders. GSA is currently focusing on the pools with the lowest spending levels. Contractors considering a bid should assess themselves against the self-scoring evaluation in the original solicitation. There are currently no minimum scores for the pools on the table.

 

OLM rule finalized

OLMs, Order-Level Materials, are goods and services that are not covered by original FSS contracts or BPAs, but are necessary to the completion of a particular order. Historically, FSS prohibited agencies from adding them into task orders and delivery orders placed against contracts. This meant agencies could only acquire them by placing task orders on multiple-award-contracts, and were hence forced to make two separate procurements. However, on January 24, FSS issued a final rule to authorize agencies to acquire OLMs when placing orders, offering greater flexibility and efficiency.

The rule makes clear that OLMs are not open-market items, but rather may be added to an order under the new GSAR provision 552.238-82. The list of schedules authorized to allow for OLMs should soon be available here. 

Under the new rule, agencies may add OLMs up to one-third the value of the order, with some restrictions. Except for travel OLMs, each proposed OLM above the simplified acquisition threshold of $150,000 should come with three quotes. This ensures that prices are fair and reasonable.

Industry partners with affected GSA FSS schedules will receive bilateral modifications from GSA adding the OLM Special Item Numbers (SINs) to their GSA contracts. Before accepting, contractors should ensure that they have policies and procedures in place to comply with the three-quote requirement and the OLM limitation of one-third of the total order value.

Overall, this looks like a welcome change that will increase efficiency and decrease administrative costs.

The Contract-Gift that keeps on giving

GSA offers continuous contracts to successful MAS contractors

With so many of our current clients approaching the sunset of their 20-year contract Schedule periods, we are pleased that GSA has finally released an official rule to help with ongoing Blank Purchase Agreements (BPAs).

In the past, the end of the Schedule options meant contractors had to perform a juggling act with their government clients to keep BPAs from becoming inactive or going to a competitor. When BPAs extend past the expiration date of their underlying MAS contracts, orders can be placed until the last day of the schedule contract, but no option periods can be used after the Schedule contract expires.

GSA has finally allowed contractors to maintain overlapping or continuous contracts. These contracts are essentially duplicate MAS contracts for different periods of performance. Holding two contracts is not mandatory, and for many contractors, would be unnecessary. But for others, it can be a business-saver.

For those that do need it, continuous contracts will allow contractors to complete work under BPAs, while simultaneously seeking new  business opportunities. Contractors should be aware that this may result in extra reporting burdens, but will be happy to know that MAS now has a streamlined process and revised requirements for previously successful contractors submitting offers for new contracts under the same schedule.

Readiness assessments, financial statements, corporate experience, open ratings report, and relevant project experience requirements have all been eliminated or greatly reduced for successful MAS contractors. To qualify, contractors must propose the same Special Item Numbers as those awarded under existing contracts, meet the minimum sales requirement under the existing contract, and demonstrate a pattern of satisfactory past performance.

For more information, check the vendor support center or contact us here at EZGSA (301-913-5000).

Done With DUNS?

GSA issues RFI for alternative to Dun & Bradstreet’s legal identifiers

GSA has issued a RFI and a draft performance work statement in pursuit of an alternative to the current legal identifiers supplied by Dun & Bradstreet. GSA is “exploring all viable means of continuing to meet its ongoing need for entity identification and validation services after the contract’s expiration.” The new RFI builds upon an earlier request from February, and primarily seeks feedback on the statement of work.

The draft states that GSA aims to fill both technical and business needs. They highlight the need to “Determine entity uniqueness, which could include the assignment and/or use of a unique entity identifier in perpetuity, validation of certain entity data, and associated services,” as well as a method of understanding the hierarchy of entities,  and “a method to determine relevant information about an entity that is being excluded from doing business with the government.”

Technical objectives include real-time data for validation services, machine-readable formatting that doesn’t require custom software, and transfer and resting data encryption. The RFI has been widely welcomed by Dun & Bradstreet, as well as other industry partners. The contract expires in 2018, so be ready for changes.