Higher federal procurement standards for IT providers – Are you ready?

The White House is spearheading an interagency endeavor concentrating on software development that will determine federal procurement of information technology (IT). In the coming weeks, vendors can expect to see new IT security standards, governmentwide. This comes after many tech companies complained that the effort under the Trump administration limited the import of information and communications technology from “foreign adversaries.” While leaving the definition of the term “foreign adversary” up to the Commerce Secretary. In addition, the rule as it stands today is broad and raises concerns over due process.

The SolarWinds breach will ultimately raise the bar on vendor security, banning tech from many countries, not just China. It also focuses on vendors and the possibility of vulnerability disclosure policies that encourage reporting weaknesses in their products. Ultimately, vendors providing IT products and services to federal agencies must have the proper level of cybersecurity in place.

Cybersecurity and Infrastructure Security Agency Acting Director Brandon Wales said agencies are working together to ensure consistency in the government’s approach to supply chain security across the Commerce Department rule, an executive order aimed at removing foreign adversaries from the bulk power sector. Wales also said, “the administration is counting on higher federal procurement standards to elevate security across the private sector as well.”

Are your IT products compliant? Give us a call.

 

 

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.

GSAmazon

GSA recently asked for feedback on proposed requirements for the upcoming e-commerce portals program. (Fedscoop, July 2, 2019)

The 2018 National Defense Authorization Act requires GSA put into place a multiple-award proof of concept site similar to those of Amazon and other large online commerce sites. This will update the way agencies purchase products outside of existing contracts. (ibid)

An estimated $6 billion is spent on open-market purchases through government-issued credit cards. The e-commerce portals program pilot will launch with hand-picked agencies and a spending limit of $10,000 on any one order. GSA is asking Congress to raise the threshold to $25,000 for the five-year pilot to better evaluate the program. (ibid)

“During the initial proof of concept, GSA will encourage robust competition through the implementation of multiple e-marketplace platforms,” said a deputy assistant commissioner at the Federal Acquisition Service within GSA. “We are looking to leverage business-to-business terms whenever practicable, to allow for streamlined buying while obtaining a more transparent and centralized view of the type of government-wide spend.” (ibid)

The goal of the Commercial Platforms Program is to start small and refine. The Commercial Platforms Initiative is just one of four Federal Marketplace Strategy projects. The draft solicitation was issued on July 2nd and is open for public comment for 30 days. (GSA interact July 2, 2019)

Interested in how you might fit into the e-commerce portals program? Give us a call.