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Selling to the government

MAS Modification Guidance

GSA used industry feedback from over 90 current schedule holders and prospective contractors, who completed the MAS Modification Guidance RFI, to create the final MAS Modification Guidance. (GSA Interact, March 6, 2020)

Here’s a quick recap of the MAS Modification Guidance RFI findings:

  • Approximately 91% of participants find the guidance clear for various types of modifications
  • 93% agree the guidance will benefit industry.
  • Approximately 75% find the price proposal template instructions clear.
  • 60% feel the price proposal template will not add an additional burden. (ibid)

Based on industry feedback, the following guidance updates are now in effect:

  • Updates to the actual guidance document to improve the flow.
  • Addition of an Executive summary section describing what to expect after a modification submission.
  • Clarification of requirements. (ibid)

Industry feedback guided the following price proposal template changes:

  • Improved instructions for the Price Proposal Template.
  • A glossary was added.
  • Additional instructions for contractors with large catalogs.
  • Designed sample Price Proposal Templates including examples of different modification possibilities. (ibid)

Some commonly asked questions from the RFI:

  1. How do contractors participate in the Transactional Data Reporting (TDR) pilot? Contractors can opt to participate in TDR by submitting an eMod request. Please review the requirement for TDR on the Vendor Support Center carefully, as it is not possible to opt-out of TDR once you opt-in.
  2. Does a modification to participate in TDR need to be processed before a contractor can omit information related to the Basis of Award/Most Favored Customer (BOA/MFC) in the price proposal template/modification guidance? Yes.
  3. Does GSA intend to standardize the modification guidance according to North American Industry Specific Classification (NAICS) code and/or Special Item Number (SIN), or will the guidance be the same for all MAS contract holders? The MAS Modification Guidance will be the same for all MAS contract holders and will allow flexibility for Large Category, Subcategory, and SIN requirements.
  4. How is GSA ensuring consistent interpretation and application of MAS Modification Guidance by contracting personnel? Training will be ongoing for GSA’s internal workforce. GSA is looking to build consistency and continuously improve the modification process across the MAS program.
  5. Are contractors required to perform market research when submitting the Price Proposal Template (PPT)?  No, but may consider in order to be competitive.
  6. Which Contracting Officer/Contracting Specialist (CO/CS) will a contractor with multiple contracts work with? Contractors will work with the CO/CS assigned to each individual contract. (ibid)

GSA expects the conversation to be ongoing with industry partners and contractors through emails and various industry days. Changes and updates will continue as necessary.

Questions about the Price Proposal Templates or the recent Mass Mods? Give us a call.

Federal Supply Schedules: VA=GSA????

Earlier this year the Government Accountability Office (GAO) released the report, “VA Acquisition Management: Steps Needed to Ensure Healthcare Federal Supply Schedules Remain Useful (GAO-20-132).” (Federal News Network, February 21, 2020)

The report dives into the non-pharmaceutical Federal Supply Schedules and lays out 11 recommendations, nine to the Department of Veterans Affairs and two to the General Services Administration (GSA). The report also outlines how the VA and GSA should address their contracting operations supporting veterans healthcare. (ibid)

For some background, the Veterans Administration manages nine healthcare-related Federal Supply Schedules (VA FSS) that provide medical devices as well as services. Included in the VA FSS are medical-surgical equipment, pharmaceuticals, patient mobility devices, laboratory testing, and analysis services. The VA FSS accounts for about $15.4 billion in annual purchases, the pharmaceutical schedule making up $12.6 billion, with the additional eight schedules coming in at about $2.8 billion. For the last four years, sales under the eight non-pharmaceutical schedules have been somewhat flat. (ibid)

It turns out that the VA and GSA have a few areas where they are lacking a “team” mentality. The GAO also finds there is limited guidance and training of the VA contracting staff and it seems the VA FSS and the VA’s Medical-Surgical Prime Vendor program are duplicating efforts. This means longer processing times for contract awards, contract mods and higher admin costs for the VA and industry as a whole. (ibid)

GAO recommends the following:

  1. The VA provide comprehensive FSS guidance and training to the FSS contracting staff
  2. The VA and GSA improve collaboration, including the potential use of GSA’s procurement tools to support the VA FSS
  3. The VA evaluate timeliness goals and barriers to achieving them in the contracting process
  4. The VA assess FSS and MSPV-NB duplication to resource utilization and leverage its buying power (ibid)

The Coalition’s “VA Multiple Award Schedule White Paper” gives recommendations to increase the effectiveness and efficiency of the VA FSS. The recommendations are:

  • Recognize commercial practices when possible
  • Consistency with GSA/FSS policy
  • Streamline the evaluation processes
  • Reduce contracting costs for the government as well as industry (ibid)

The white paper goes on to make specific recommendations to align the VA’s price negotiations strategy with GSA’s approach. Additionally, the white paper touches on the use of GSA’s e-Offer and e0Mod systems to streamline the procurement process. As it turns out, the VA and GSA have very different approaches to contract audit support for their FSS programs. The white paper recommends the two align with GSA’s approach. (ibid)

Will there be more opportunities to work with the VA once their processes are synced up to GSAs? Give us a call.

Lead Times! Get Your Lead Times Here!

When is the actual start and end of Procurement Administrative Lead Times (PALT)? The Office of Federal Procurement Policy (OFPP) is working on a measurement to answer this question, which seems to be not only a grey area in the procurement arena but a disputed one, as well.

OFPP is looking at the 2019 National Defense Authorization Act, section 878, which describes PALT as “the time between the date on which an initial solicitation for a contract or order is issued by a federal department or agency and the date of the award of the contract or order.”  OFPP would like to marginalize procurement process delays and believes having this definition in place will minimize those delays. (FCW, February 24, 2020)

The Professional Services Council and the Council of Defense and Space Industry Associations both welcome the definition being put in place. However, naysayers argue the OFPP language misses pre-solicitation work, such as: creating a requirements planning package that provides solicitation facts prior to issue; or when a particular contract is initially funded. According to some, the current definition ignores pre-solicitation lead time factors which do contribute to the time needed for a contracting officer to move from contract request to contract requirement in solicitation. (ibid)

Wondering how this affects your upcoming proposal efforts? Give us a call.

beta.sam.gov Hiccup Hiccup

When FedBizOpps (FBO) migrated to beta.sam.gov, everyone expected a few hiccups. Now three months in, it’s fair to say government contractors have been experiencing more than just a few hiccups. GSA says the number of help desk calls they get is no more than they got with FBO. However, the frustration over beta.sam.gov runs deep.

Last week contractor discouragement came to a head when the Professional Services Council sent GSA a letter airing not only their complaints but also their concerns. The 22-page letter outlined the four areas of greatest concern:

  • Access Challenges;
  • Search Parameters;
  • Capability to receive contract information;
  • Difficulties in how the site displays information. (Federal News Network, February 17, 2020)

At EZGSA, we have found problems with data organization, standardization, and even saving information. GSA seems ready to add new capabilities next month, but should they? Many feel the backend structure should be fixed before the next phase, moving the Federal Procurement Data System-Next Generation (FPDS-NG) reporting capabilities to beta.sam.gov in March. (ibid)

Large companies are better able to handle the costs associated with down time or lost data. Small businesses that must  spend thousands of dollars on software, just to get what they got before the FBO migration, are at a great disadvantage.

Need help navigating beta.sam.gov? We will do our best to help and take away some of the frustration. Give us a call.

New Cybersecurity Certification Requirements

The Office for the Under Secretary of Defense and Sustainment (OUSD (A&S)) recently released its Cyber Security Maturity model Certification (CMMC). DoD stakeholders, University Affiliated Research Centers (UARCs), Federally Funded Research and Development Centers (FFRDCs) and the Defense Industrial Base (DIB) all had a hand in developing the CMMC model. This model measures cybersecurity maturity using five levels (from basic to advanced) and aligns a set of processes and practices with the type and sensitivity of the information to be protected and any associated threats to that information. (CMMC Model v1.0, January 30, 2020)

DoD’s CMMC enhances the protection of:

  • Federal Contract Information (FCI) provided or generated by the government, but not intended for public release
  • Controlled Unclassified Information (CUI), which requires safeguarding or dissemination consistent with laws, regulations and government-wide policies. (ibid)

The CMMC model includes the safeguarding requirements for FCI spelled out in FAR clause 52.204-21 and the security requirements for CUI stated in the National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171 per DFARS clause 252.204-7012 [3,4,5].

Included in the CMMC model is a certification piece verifying the implementation of cybersecurity maturity measure processes and practices. This is intended to deliver assurance to the DoD that contractors and subcontractors can sufficiently protect CUI at a level equal to the risk. (ibid)

To obtain a full overview of the CMMC Model, domains, practices, and processes, please review the Cybersecurity Maturity Model Certification.

Have questions about the effect on your current contract or one in works? Give us a call.