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Tag: OLM

GSA contracting just got a whole lot easier – well, maybe

This past May, the General Services (GSA) issued Refresh #6 to the Multiple Award Schedule (MAS) Program solicitation. The goal of Refresh #6 is to modernize and simplify the way contractors do business with the Federal Government. (SecurityInfowatch.com June 14, 2021)

Some of the most significant changes are:

  • Establishment of a Verified Products Portal (VPP). The VPP aims to keep vendors from unauthorized selling of products to the government, under the Federal Supply Schedule.  In most cases, manufacturers who did provide a Letter of Supply (LOS) to resellers will use the VPP as an alternative authorization. (The VPP will not replace GSA Advantage or the SIP program, see VPP@gsa.gov)
  • COVID-19 Waiver which creates a temporary waiver for some requirements of the GSA submission application for vendors who offer products or services supporting the government’s response to COVID-19. The two-year corporate experience requirement is waived.
  • MAS contract cancellation deferrals. This is extremely helpful to contractors who haven’t met the minimum sales requirements per the I-FSS-639 Contract Sales Criteria.
  • Consolidation of the GSA Schedules Program. GSA, by consolidating, hopes to eliminate duplication and standardize processes while at the same time updating terms and conditions. The original 25 GSA Schedules became one, with 12 large categories and 83 subcategories. Contractors may now add new SINs beyond their legacy SINs previously awarded. Current GSA contractors had their awarded SINs mapped to new SINs that correspond to NAICS Codes. (All integrators and contractors are advised to speak with their Contracting Officer to figure out the next steps for SINs from a different large category.)
  • Order Level Materials (OLM) SIN added across all categories. OLMs are acquired at the order level giving the contracting officer (OCO) responsibility for making a fair and reasonable price determination. OLMs are authorized for use in direct support of another awarded SIN, they are not Open Market Items.
  • Phase III of the MAS Consolidation requiring all current contractors to consolidate their contracts under one unique identifier  – Dunn & Bradstreet number. This gives contractors a single point of contact within GSA. GSA provides Modification Guidance with each refresh. Contractors should register for the GSA FAS ID and keep passwords up to date.
  • Unique Entity Identifier (UEI) will be issued to contractors in early 2022. This identifier will eliminate the usage of the Dunn & Bradstreet number as a contractor’s government identity. For contractors registered in SAM.gov, the process will take place automatically. (ibid)

GSA is making some major changes over the next 12 months to their GSA Schedules Program. However, the Cybersecurity Maturity Model Certification (CMMC) is not expected to be included in the MAS solicitation. Agency-specific requirements for technical certification will be outlined in each specific request for quotation. (ibid)

Are any or all of the above changes a little confusing? 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.

OLMs in Your MAS … Finally!

In an effort to create consistency between the Multiple Award Schedule (MAS) and other IDIQ contracts, GSA has incorporated Order Level Materials (OLMs) into the Schedules through a final General Services Acquisition Regulation (GSAR). This change gives agencies flexibility, which should ultimately result in more consistency. (GSA Interact February 12, 2019)

The GSA Federal Acquisition Service (FAS), Integrated Workplace Acquisition Center (IWAC) plans to refresh the following Schedule solicitations in early Spring 2019 to implement the OLM authority:

  • 36 Office, Imaging, and Document Solutions
  • 58 I Professional Audio/Video Telemetry/Tracking, Recording/Reproducing and Signal Data Solutions
  • 78 Sports, Promotional Outdoor, Recreation, Trophies, and Signs (Sports)
  • 72 Furnishing and Floor Coverings
  • 71 II K Comprehensive Furniture Management Services (CFMS) (ibid)

GSA will issue a bilateral mod to incorporate the planned changes into existing contracts. Contractors may accept the modification, as it will be optional. MAS contractors must either accept or decline the mass mod within 30 days of receipt. After acceptance, OLM SIN and OLM terms and conditions will automatically be added to existing contracts. If contractors do not accept the modification, they may not provide OLMs in response to customer requirements. (GSA Interact February 12, 2019)

If you’re having trouble deciding about whether to accept the mass mod, give us a call at 301-913-5000, and we’ll talk it out with you.