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.

Bots Can be Your Friend

It’s been just about a year since Dr. Michael Wooten, the Policy Administrator for the Office of Federal Procurement, disclosed his plan to remove friction from the acquisition process. His intention is to rely on robotics process automation (RPA) as well as a few additional concepts to lessen the burden on contracting officers. (Federal News Network, October 12, 2020)

One way Wooten plans to do this is through the reduction of procurement administration lead time. Wooten recently spoke at the ACT-IAC Acquisition Excellence conference and said, “We look to accelerate the use of facilitated requirements development workshops, known as SAWS. We should enhance the requirements development process with the same technologies used to finish my sentences when I send texts or emails. This is no pie-in-the-sky vision. The technology exists today. In fact, the Department of Interior is piloting this approach. Under one of its contracts, a contractor supporting the Department of Interior applies natural language processing and machine learning tools to coach Interior’s acquisition community through the acquisition process. These artificial intelligence tools collect data to identify training needs. These data support management decisions to support better performance through training or process improvements.” (ibid)

When purchasing anything from help desk services to a fighter jet, AI and natural language processing tools pull clauses and requirements, which are applicable, by scanning previous contracts. The next step hopefully finds the manager performing minor tweaks to the language because most of the language has been used previously. GSA has been using these facilitated requirement development workshops (SAWS) since 2015 for BPAs and DoD has used SAWS since 2012 for service acquisitions over $1 billion. (ibid)

The acquisition community is taking a hard look at automation. RPA has been applied to the procurement process by the IRS, the Army, and GSA. Wooten feels RPA will improve compliance and ultimately become routine. He said, “these process automation tools can take on the ‘flow-chartable’ tasks. These tools will execute program decisions. In this fashion, automation can enable a compliance system that enables greater speed and accuracy. As process automation tools take on program decisions, they free people to make non-program decisions. They free people to exercise critical thinking and professional judgment. They empower people to create solutions.”

IRS has two programs under the Pilot IRS initiative:

  • Contract Clause Review:  a tool allowing a procurement document to be uploaded while answering questions about the document. Within seconds a compliance report is generated. Missing characters, text, and incompleteness is checked while at the same time syncing to the FAR, the Treasury Acquisition regulations, and the IRS acquisition policies. The tool is expected to have a large Return on Investment.
  • Contractor responsibility determination will automatically, prior to contract award, verify a company is eligible to do business with the government. Instead of a manual process, a bot will search databases, sending a report back to the employee within five minutes.

The Army launched another form of automation, a bot to retrieve information from SAM.gov and FAPIS.gov and summarize the information in a formatted template. Air Force and Navy should be utilizing the bot in fiscal 2021. Liz Chirico, the acquisition innovation lead in the Office of the Deputy Assistant Secretary of the Army for procurement said, “our team is looking into a couple of other interesting intelligent automation ideas. We are looking at automating some of the manual lookup processes for pricing so going to some of the public-facing pricing sites like GSA’s CALC and the Bureau of Labor and Statistics are two examples. We are also looking into streamlining the acquisition requirements process. That process often takes a lot of time and requires duplicative information, so if there is any way for us to streamline that and have all of the requirements stated upfront and have those templates and forms prepopulated.” Bots will probably also be used to ensure compliance with Section 889, prohibition of Chinese made telecommunications products. (ibid)

The IRS and the Army are using automation tools to move quickly through the procurement process and it’s likely the rest of the federal agencies are not far behind.

Questions concerning an upcoming bid and your company approvals through RPA or other automation processes? Give us a call.

Is it Beta, Old, or New SAM?

Over time, GSA is transitioning reporting tools to beta.SAM, while the original SAM.gov remains live. Although the final site will also be called SAM.gov, it will be much different than the current one. When the full functionality of the new SAM.gov is moved over to beta.SAM, the latter will lose the “beta” prefix and the old SAM.gov will simultaneously be retired. Confused yet? (Nextgov September 11, 2020)

According to Judith Zawasky, assistant commissioner for the office of systems management in the Federal Acquisition Service (and former EZGSA employee!), “the new site is on track to lose its “beta” designation in 2021.” Zawasky is trying to ensure that remaining transition areas and training are smooth. The soft launch is expected to be finished by 17 October, and after that date, users will no longer be able to run reports on the FPDS.gov site. Searches will remain part of the site for a slightly extended period. Zawastsky noted that what remains of the transition to the new SAM.gov may not be completed before 2025. (ibid)

The final SAM.gov site will include FBO, under Contract Opportunities; FPDS, under Data Bank; the original SAM.gov; the grants site Catalog of Federal Domestic Assistance, CFDA; Wage Determinations Online, WDOL; Electronic Subcontracting Reporting System, eSRS; the past performance databases, the Federal Awardee Performance and Integrity Information System, FAPIIS, Contractor Performance Assessment Reports System, CPARS, and Past Performance Information Retrieval System, PPIRS; and the Federal Funding Accountability and Transparency Act, FFATA. (ibid)

Can’t find what you are looking for on any site? Give us a call, we can help.

Emergency Rules

Government ontractors and small businesses should be aware of increased opportunities during the current COVID-19 national emergency. The government is permitted, during a national emergency, to set aside solicitations to allow awards “only to offerors residing or doing business primarily in the area affected by …[a] major disaster or emergency.” Contractors can verify if they fall into this category by reviewing Federal Acquisition Regulation 52.226-3(d). (Law360.com, April 13, 2020)

A national emergency declaration allows the government to (restrict) certain solicitations to small businesses in certain areas. These solicitations are either a set-aside or an evaluation preference is given to small businesses. (ibid)

During national emergencies, large contractors should look to team with small businesses, or to current teaming agreements already in place. In addition, contractors who are at the ready to produce/provide goods or services may be called on to contract with agencies to battle COVID-19. (ibid)

Micro purchase thresholds are another acquisition procedure government agencies may use during a national emergency. These allow for a simplified acquisition methodology for specific items or services required under emergency situations, such as the COVID-19 national emergency. (ibid)

State and local governments may also procure under the Stafford Act, wherein state governors request financial relief via federal grants that allow procurement under their own procedures. The Stafford Act authorizes federal contracts for “debris clearance, distribution of supplies, reconstruction, and other major disaster or emergency assistance activities.” In 2006 the Local Community Recovery Act amended the Stafford Act mandating local organizations to be given preference when using full and open competition. The FAR was also amended to align with the Local Community Recovery Act. Under the act, if a contractor does not meet all of the Recovery Act stipulations there are other factors that may be considered. (Contractors may self-certify that they are local.) (ibid)

Other streamlining acquisition procedures are available under federal supply schedule contracts, multi-agency blanket purchase agreements, and multi-agency indefinite-delivery contracts. Additionally, there is an easing of the requirement that a contractor be registered in SAM.gov at the time an offer is submitted to the government. (ibid)

The emergency declaration allows state and local governments to purchase from all GSA schedules. It also encourages accelerated payments to small business contractors.  (ibid)

Additional modified procedures to facilitate swift responses are:

  • Relaxation of qualifications requirements
  • Use of sole-source contracts
  • Use of oral requests for proposals
  • Use of letter contracts
  • Interagency acquisitions
  • Awards to small disadvantaged businesses
  • Retroactive overtime approvals
  • Waivers of bid guarantees when an emergency exists
  • Use of protest overrides where necessary for a contracting process to continue

In order to track procurements related to COVID-19, GSA added a National Interest Action (NIA) code to SAM.gov. To find information on the site, simply type COVID-19 2020 in the search bar. (ibid) Contractors can register with SAM.gov under the disaster response registry, and be sure to monitor the portals most closely aligned to the goods or services you provide.

Have questions about the many opportunities available under the current national emergency? Give us a call.

Emergency Relief for GSA Schedule Holders

GSA is instituting a 60-day extension to SAM.gov registrations with an expiration date between March 19 and May 17, 2020, to provide relief for those required to re-register during this time frame. (GSA Interact, March 24, 2020)

For example, if your entity registration is set to expire on April 1, 2020, you are granted an automatic extension to May 31, 2020. No action is required, other than to get re-registered by your new extension due date. (ibid)

GSA plans to process the extensions gradually to lessen the impact on their interfacing systems. Therefore, the entity administrators who are affected by the extension will receive an email with the subject line: “60-day SAM.gov Extension Granted for [Entity Name/DUNS/CAGE]. (ibid)

Once the records are extended, the revised expiration dates will be included in the SAM entity management extracts. (ibid)

Unclear if you are one of the 61,298 entities impacted by the extension? Give us a call.