CMMC in GWACs

GSA is expected to begin applying the Department of Defense’s Cyber Maturity Model Certification (CMMC) at the order level to governmentwide acquisition contract vehicles. (Govconwire, November 10, 2020)

According to Keith Nakasone, deputy assistant commissioner for acquisition in the General Services Administration Office of IT, future Government Wide Acquisition Contracts (GWACs) will include CMMC requirements, layered in over time. In this video interview, Nakasone explains that the requirements are being added to make sure contracts are within scope for the Department of Defense, the largest GWAC customer. (Government Matters, November 8, 2020)

Nakasone hopes to educate and train industry partners on the CMMC requirements over time. Although he didn’t state outright that CMMC will become part of all future contracts, they are part of the Polaris draft RFP, scheduled for release in December. (ibid)

Need assistance in understanding the CMMC requirements? Give us a call.

DUNS Isn’t Done, Yet

The government is extending the transition time from DUNS Number to UEI (unique entity identifier.) OMB is directing the transition to take place by April 2022. Additionally, GSA is contracting with Dun & Bradstreet (the creator of DUNS numbers) to make sure the transition period is a smooth one. (GSA Interact, October 26, 2020)

Going forward, vendors will request their identifier from within SAM.gov, there will be no third party involvement. SAM.gov will generate the unique entity ID or UEI for each new vendor during registration. Active SAM.gov registrants will have their UEI assigned and viewable. There is no further action required of currently registered vendors, at this time. (ibid)

Need assistance with SAM.gov or registering for your UEI? Give us a call.

Digital Certs, Out; Docusign, In

As of 30 November 30, all Multiple Award Schedule (MAS) holders are required to use DocuSign to digitally sign Documents in eOffer and eMod. (GSA Interact, October 28, 2020)

Additionally, GSA plans for the eOffer and eMod system to join FAS systems, including FAS Sales Reporting Portal (SRP), GSA Advantage Purchase Order Portal, GSA Vendor Portal, eBuy Seller, and the Mass Mod Portal, using GSA’s FAS ID multi-factor authentication (MFA). GSA’s FAS ID, allows contractors to access GSA applications using a single email and password. This transition will take place in Q2 of 2021.

During 25 – 29 November, contractors and offerors will not be allowed to submit offers and/or requests for modifications in eOffer and eMod. GSA advises planning ahead! If your document requires a contracting officer’s signature, it must be obtained by 23 November 2020. (ibid)

Digital certificates are required until the transition to DocuSign and GSA FAS ID is complete. Although digital certificates are not required once DocuSign is complete, those certificates may be required by other government agencies or private companies, therefore GSA advises holding onto your hard copies. (ibid)

Scrambling to get those documents signed by November 23rd? Give us a call.

 

 

New and Improved CPARS. When?

The Office of Federal Procurement Policy recently conducted a survey with a host of agencies regarding contractor performance assessment ratings (CPARs) and if they are completed at all, they are not on time.  (Federal News Network, October 5, 2020)

Working with GovConRx, OFPP found 95 percent of respondents would actually like to take part in contractor self-assessments at agreed-upon intervals throughout the contract performance period. A majority of respondents (84 percent) support a “CPARs Lite” perspective for certain fixed price and commercial item contracts as well as CPARS ratings demonstrating specific objectives and contract outcomes. It appears many agencies are doing their “own thing” right now; for instance, OFPP and DHS have launched pilot programs using artificial intelligence to gather data and complete the ratings. VA also has its own program to review key performance indicators.(ibid)

What does all this mean? Changes to CPARs is necessary and on the horizon. Unfortunately, there is still no timeframe for how soon we will see them.

Questions about CPARs and how they might work to help you with future procurement efforts? Give us a call.

DoD and Software

The Department of Defense is updating its purchasing policies for software acquisition, moving toward an  Adaptive Acquisition Framework. (fedscoop, October 7, 2020)

DoD’s new software purchasing policy includes some big changes: its focus will be on updating software on an “as needed” basis instead of custom coding. In the old model DoD purchased software in the same manner as it bought tanks, which often took years. The new policy, titled 5000.87, allows contracting officers to have the tools they need to buy code while giving them the flexibility to focus on the development and maintenance of programs. (ibid)

According to a DoD spokesperson, “as more parts of the military use similar technology-development stacks, achieving Authorities to Operate (ATOs) will happen much faster.” The goal is to improve cycle time which should now be achieved with the new framework in place.

Are you looking to work with DoD to provide software or code and have questions about how to get started under the new purchasing policy? Give us a call.