It’s Heeeeere…

The new, single GSA Multiple Award Schedule solicitation was released today, 1 October, and it’s mostly what we expected.

Solicitation number 47QSMD20R0001, refresh 00 (!!) points you to the correct NAICS number for your product or service. The first page of the solicitation references the MAS Roadmap, which includes a guide to preparing your offer and required forms such as the:

  • Agent authorization letter
  • Letter of supply
  • Categories and appropriate NAICS (formerly SIN) numbers
  • Labor category matrix

as well as information about the:

  • Price proposal template, pricing narrative, and pricing support
  • Financial statements
  • Subcontracting plan
  • Technical proposal
  • Professional compensation plan
  • Commercial supplier agreements
  • Previous cancellation and rejection letters
  • Commercial sales practices
  • Commercial or market pricing

You must download separate documents, depending on your proposed product/service. Option categories include: office management, facilities, furniture and furnishings, human capital, industrial products and services, information technology, miscellaneous, professional services, scientific management and solutions, security and protection, transportation and logistics, and travel.

The old standards survive. You must submit via eOffer, the pilot TDR still applies, and you must sell $25,000 per year from the Schedule to keep it. Pathways to Success and the Readiness Assessment remain, as does AbilityOne and SCA.

All service AND product offers must now provide corporate experience and quality control narratives. Furthermore, you now have the option to submit CPARS reports instead of Open Ratings or even a narrative if your company hasn’t six references required by Open Ratings. One positive: GSA now requires only one past project description per service.

The following ominous clause has been included: “The offeror must provide a full and broad array of proposed products/services. An offer will not be accepted with limited product/service offerings unless it represents a total solution for the offeror or proposed product/service offering.” Will small, niche businesses have a more difficult time obtaining an award? Hope not.

Also, until SAM has added representations for the new FAR clause regarding covered telecommunication equipment and services (see our Blog post from 10 September) from particular Chinese companies, proposal submissions must include a statement noting compliance with n 52.204-24 Representation Regarding Telecommunications and Video Surveillance Services or Equipment.

Once awarded, yearly increases for contractors will be capped at four percent for the Human Capital Category, five percent for Professional Services and Travel, and ten percent for all others.

Yes, it’s complicated, and yes we have a handle on it. We are primed and ready to answer all your questions either about a new proposal or your current Schedule. Just give us a call.

Time to Uncover Some Chinese Equipment

Recently, GSA sent a letter to contractors explaining the new FAR interim rule regarding supply chain security, which went into effect last month. The rule prohibits federal agencies from procuring, obtaining, extending, or renewing a contract to procure or obtain “any equipment, system, or service that uses covered telecommunications equipment or services  as a substantial or essential component of any system or as critical technology as part of any system.” (Acquisition.gov)

Covered equipment encompasses telecommunications and video surveillance products and services by Hauwei Technologies Company, ZTE Corporation, Hytera Communications Corporation, Hikvision Digital Technology Company, or Hahua Technology Company, or any company that the head of a relevant federal agency reasonably believes is controlled by the government of the Peoples Republic of China.

The interim rule:

  • Prohibits contractors from providing covered telecommunications services/equipment unless an exception or waiver is granted
  • Mandates every offeror represent whether it will provide covered telecommunications equipment/services as part of its offer, and if that is the case, the offeror must provide details about the covered equipment or services
  • Requires contractors to report any covered equipment/services throughout the life of the contract. (ibid)

At the same time, the FAR interim rule went into effect, GSA issued a class deviation. This essentially takes a risk-based approach to the new FAR interim rule by limiting the representation requirement for GSA funded orders to the indefinite-delivery contract level. The deviation necessitates the following:

  • At all times requires an order-level representation for acquisition vehicles that carry a “high risk” of including covered telecommunications equipment or services.
  • Must have an order-level representation for all orders that could include information technology or communications technology under all GSA acquisitions.
  • The creation of a GSA Acquisition Regulation (GSAR) representation clause, requiring the GSAR and FAR reporting clauses in all new and ongoing GSA contracts.
  • Initiates GSA specific implementation targets for modification of existing contracts.
  • Simplifies the application of Section 889 of the NDAA to other GSA program areas. (ibid)

The interim rule affects ALL contractors. As a contractor, you are responsible for determining whether covered telecommunications equipment/services will be provided under both new and existing contracts and orders.

Below is some fundamental information to help you prepare as GSA puts into place the interim rule and class deviation:

  • FAS contracting activity will issue a mod requiring you to respond to incorporate FAR clause 52.204-25 and GSAR clause 552.204-70.
  • Your mod response must delineate if you will or will not provide covered telecommunications equipment/services in the performance of any contract, subcontract, order, or any other contractual instrument.
  • The substance of FAR clause 52.204-25 must be inserted into all subcontracts.
  • You must report any covered telecommunication equipment or services you discover during the course of contract performance.
  • For new GSA solicitations, you are required to represent at the contract level if you will or won’t provide covered telecommunications equipment/services to the Government in the performance of a contract or subcontract.
  • Contract level solicitations will include FAR provision 52.204-24, clause 52.204-25and GSAR clause 552.204-70.
  • In responses to solicitations and orders under indefinite-delivery contracts, representation of FAR 52.204-24 is required when there is a high risk of inclusion of covered telecommunications equipment/services. (ibid)

Wondering how all this might affect your current contract or upcoming bid? Give us a call.