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Contract management

Yes Virginia, There Is a Data Ethics Framework

Earlier this month, GSA was given the opportunity to develop a Data Ethics Framework to assist agencies in making ethical decisions as they acquire, manage, and use data. A completed version of the report is expected by the end of 2020. (GSA Data ethics framework action 14 draft, September 2020)

The Framework incorporates four parts:

  • About the Data Ethics Framework — explains the purpose and audience of the Framework.
  • Data Ethics Defined
  • Data Ethics Tenets — provides seven principles for using data ethically within the federal government.
  • Data Ethics Tenets in Action — details data ethics benefits and demonstrates how the Tenets guide data activities within agencies as well as federally sponsored programs. (ibid)

The Framework originated to guide ethical decision making by federal employees who collect, manage, or use data to support their agency’s mission. It acts as guidance to encourage ethical decision making, but isn’t required. Its audience includes “anyone in the Federal Government who works with or leads work involving data, which includes all employees, contractors, researchers, and other partners who work on behalf of the government.”

According to the Framework, “Data leaders and professionals should adhere to all applicable legal authorities, as ethics are reflected and reinforced in existing laws.” Additionally, “agency leaders are encouraged to maintain up-to-date, comprehensive ethical standards regarding data use and staff are responsible for learning and applying agency guidance. In addition, if a person works in an area with recognized professional ethical codes of conduct, they should be aware of those standards and strive to uphold them.” (ibid)

Have a question about the Framework or the definition of data ethics? Give us a call we can explain.

Leftover BPAs

If you have a Blanket Purchase Agreement (BPA), you may have just been given a bit of a reprieve regarding the merge into the General Services Administrations’ (GSA) consolidated Multiple Award Schedule. (Federal Computer Week, August 31, 2020)

According to GSA Administrator Emily Murphy, GSA is allowing a few BPAs to work through their lifecycles as opposed to forcing them into the consolidated Multiple Award Schedule. Murphy feels it could take up to five years to move completely over to the consolidated schedule but counts on it being much sooner.

As of the end of July GSA moved to Phase 3 of the MAS consolidation. Nearly 100 percent of vendors have updated their contracts and terms and conditions for the new solicitation. Murphy said, “We’ve got 99 percent of them onboard,” and will “work with [the remaining ones] on the best way to transition.” (ibid)

Wondering about your long-standing BPA? Give us a call.

SubK Silver Lining

The U.S. Small Business Administration (SBA) is extending the time for contractors to file Individual Subcontracting Reports (ISR) by 30 days and Summary Subcontracting Reports (SSR) by 60 days. (Small Business Administration Extension Notice, August 27, 2020)

SBA reasoned that, due to the pandemic and social distancing requirements in a number of states including the District of Columbia, many records remain unattainable. Without proper records, contractors are not able to meet reporting requirements.  New deadlines for ISRs is 30 November 2020 and for SSRs is 30 December 2020. SBA is also extending the deadline to 30 November for vendors who have recently completed contracts or will complete contracts before 30 September. No financial or liability consequences will be imposed on contractors for taking advantage of the updated deadlines.

The extension notice is being sent to those on the SBPAC list as well as all government and business personnel with a valid email in eSRS. (ibid)

Not sure if the extension notice applies to you? Give us a call.

Seeing STARS

The 8(a) STARS II contract has roughly 800 small business contractors that furnish custom IT services-based solutions tailored to meet government agency needs. STARS III contract will soon replace the current STARS II contract, with a higher dollar threshold and customized IT solutions. (Federal Computer Week, August 21, 2020)

Over the life of 8(a) STARS II, GSA has repeatedly raised the ceiling to meet federal agency needs and to support their small business contracting objectives. In April of this year the contract reached a $15 billion ceiling and by the end of July is was at $22 billion. In an effort to meet growing government agency needs, the 8(a) STARS III contract will accommodate more bidders with a $50 billion ceiling. 8(a) STARS III focuses on new technologies as well as meeting the needs of federal agencies outside the continental U.S.

According to Alan Chvotkin, executive vice president and counsel at the Professional Services Counsel, “rules have changed a lot over the years, the current contract vehicle, dating back to 2011 is kind of clunky and not as nimble as newer contracts. The new contract will help GSA fine new technology companies as well as requalify existing companies.” (ibid)

Questions about the 8(a) STARS III contract and if you currently do business under 8(a) STARS II how you will requalify? Give us a call.

Paying for COVID Absences

DoD has been steadily compensating contractors for work they are not able to complete due to the pandemic. According to Ellen Lord, chief acquisition chief for the Pentagon, payments are about to speed up. (Federal News Network, August 14, 2020)

Lord explained, “We have developed a streamlined path forward for low dollar value reimbursements under $2 million, and a path to settle globally at a company or division level that will eliminate the need to have proposals and negotiations on the contract-by-contract basis.”  DoD plans to make payments based on a tiered structure, depending on the size of the payments.

Questions about getting paid during the pandemic, or if you will get paid? Give us a call.