Not a “tricky” October 31st Deadline

A Multiple Award Schedule deadline is fast approaching. All contractors must do the following to remain in compliance with the MAS Consolidation Mass Mod A812:

  1. Update your catalog in GSA Advantage
  2. Update your Price List (text file) (GSA Interact September 8, 2020)

To remain in GSA Advantage, your SIP or EDI catalog to the consolidated MAS SINs must be updated before October 31, 2020, or you risk disruption to your catalog status or access to eTools. To accomplish the update, see the SIP/EDI Catalog Update Guide. All catalog submissions must be approved by your CO. (ibid)

Additionally, all schedule holders must update their Price List (Text File) using the MAS Consolidation Price List Guide, organizing their contract offerings under the new SIN structure. (ibid)

To aid contractors with their updates, webinars are being offered as well as a Vendor Support Center Help Desk at vendor.support@gsa.gov or call 877-495-4849. (ibid)

Having trouble getting your questions answered? Give us a call.

New SIN for Office Admin Services

Under the new Multiple Award Schedule, GSA is changing the Special Item Numbers (SINs) in the Office Management and Human Capital large categories. GSA’s Northeast and Caribbean Supply and Acquisition Center and the Office of Customer and Stakeholder Engagement (CASE) are adding the new NACIS-based SIN56110 for Office Administrative Services. In addition, GSA is combining the two current SINs for Human Resources Line of Business into SIN 541612LOB. These changes all take effect on 1 July 2020. (GSA Interact June 24, 2020)

SIN 56110 will make it easier for searching and identifying specific support services to meet mission-critical needs. These services include a range of day-to-day activities, such as office administrative support, data entry, payroll administration, recordkeeping, travel preparation, scheduling, meeting management, purchasing supplies, and logistics.

To better meet agency needs, GSA is merging two SINs of the consolidated schedule, into one new SIN. The two SINs 541612OPM and 541612PSSC will be combined into 541612LOB. This new SIN provides technology solutions in support of other SINs in the Human Capital category. This category may include software, technology, systems, and related solutions. To be a function under this SIN, the services and products offered must support one or more of the 15 functions/54 sub-functions in the human capital lifecycle. To obtain a list of theses functions, visit the Human Capital Business Reference Model (HCBRM).

GSA is holding a webinar tomorrow, Friday, 26 June 2020, to review details and answer your questions. The link to join the webinar is https://meet.gsa.gov/r2newsins/. (ibid)

Questions about the Office Management and Human Capital large categories? Give us a call.

Phase 2: Resistance is Futile

Although we covered this last month, it’s worth another review  as GSA moves to phase two of the MAS consolidation.

As you know, GSA is merging the Multiple Award Schedule (MAS) program contracts from 24 different schedules into one. Notices of changes to terms and conditions for current contract holders under the MAS program should be received by contract holders in the coming months.

The consolidated schedule makes it simpler for the government to make purchases and will roll out in three parts:

  1. Creation of a new contract vehicle for all future acquisitions
  2. Bring current contract holders onto the new consolidated schedule
  3. Consolidate those businesses that have multiple contracts across many schedules(Federal Times January 31, 2020)

Terms and conditions are being standardized and all current contract holders and contractors, placed on the consolidated schedule, must respond to them by July 31, 2020. (ibid)

Questions about the consolidation and how you and your contracts are affected? Give us a call.

FAR 51 Deviation Authority is expired!

Here’s what you need to know.  Contracting officers were permitted to give contractors access to the Federal Supply Schedule (FSS) and GSA Global Supply Programs if appropriate, for the fulfillment of their agency requirements. They used the FAR 51 Deviation Authority vehicle for this purpose. On 23 October, the FAR 51 Deviation expired. It will no longer be used on orders placed after this date. Under Refresh 1, clause CI-FSS-056 Federal Acquisition Regulation (FAR) Part 51 Deviation Authority (Federal Supply Schedules) (Jan 2010) is deleted.

In lieu of FAR 51 Deviation, agencies may use Order Level Material (OLM) procedures to acquire other direct costs (OCDs) and material support items to meet specific order requirements. Additional information for OLMs may be found at www.gsa.gov/olm.

Many question if a contracting officer can issue a letter of authority (required by the Deviation) anytime during the life of the order, if the order or BPA was awarded on or before 23 October 2019. The short answer is yes, as long as the order was issued prior to the 23 October Deviation expiration date. However, if the BPA was awarded prior to then, and subsequent award terms were awarded after 23 October, those subsequent award terms may not use the deviation.

Wondering if you are grandfathered in and still able to take advantage of the FAR 51 Deviation Authority? Give us a call.

Open Ratings Closed

Open Ratings stopped accepting new orders for Past Performance Evaluations as of Friday, 6 December 2019. All Multiple Award Schedule (MAS) offerers must now demonstrate a sample of past performance by using one of the methods outlined by the solicitation:

  1. verify in eOffer there are three or more CPARS assessment reports that meet the solicitation criteria outlined in SCP-FSS-001 (j)(2)(ii)(A) or
  2. submit a past performance record and list of customer references as outlined in SCP-FSS-001 (j)(2)(ii)(C) when the offeror does not have CPARS assessments that satisfy the solicitation criteria in SCP-FSS-001 (j)(2)(ii)(A).  GSA will contact all customer references and request they complete a past performance questionnaire. Note – offerors should not upload completed past performance questionnaires with the MAS offer. (GSA Interact, December 18, 2019)

An offeror’s demonstration of past performance is limited to the methods spelled out in the solicitation. Additionally, GSA will not accept Dun & Bradstreet reports in lieu of the Past Performance Evaluation prepared by Open Ratings. Any offerors who ordered an Open Ratings Past Performance Evaluation on or before December 6, 2019, can use SCP-FSS-001 (j)(2)(ii)(B) to demonstrate a pattern of Past Performance if the Open Ratings Past Performance Evaluation uploaded to the offer is dated within one year of the offer submission and the offeror had no CPARS assessments that satisfied the solicitation criteria as spelled out in the SCP-FSS-001 (j)(2)(ii)(A). (ibid)

Is this all perfectly clear? If not, give us a call and we can walk you through the steps to demonstrate the acceptable Past Performance for a MAS offer.