Skip to content Skip to left sidebar Skip to right sidebar Skip to footer

Contract management

A workflow for everyone


The Catalog Management Office (CMO) is actively finalizing the workflow for Multiple Award Schedule (MAS) services between eMod and the new FAS Catalog Platform (FCP). Simultaneously, they are completing the new Services Plus File for FCP use, marking progress towards launching MAS service functionality in FCP by fiscal year-end 2024 (refer to the attached file for the Services Plus file). (BUY.GSA.GOV NOVEMBER 30, 2023)

The Services Plus file, formerly the Service File, will now accommodate all service contract and catalog data from the Services and Training, and the Language Services Price Proposal Templates. Vendors will also utilize it for non-GSA Advantage! publishable products, such as highly customizable items. (ibid)

Vendors can categorize their offerings in the new template under eight catalog item types:

  1. Commercial Labor Categories: Vendor-defined labor categories, using the hour (HR) unit of measure.
  2. Service Contract Labor Standards (SCLS) labor categories: Governed by Service Contract Act laws and regulations, using the HR unit of measure.
  3. Fixed Price Solutions: Services outside the labor category paradigm, using any unit of measure.
  4. Courses and Training: Sessions with minimum and maximum student constraints.
  5. Other Direct Costs (ODCs): Contract-level items sold, supporting public relations and marketing services.
  6. Language Services: Translation services, translating languages, one or both ways.
  7. Highly Customizable Products: Products with multiple options, that cannot be sold on GSA Advantage! Priced as a discount to a manufacturer group or family, as opposed to pricing products as a discrete set of line items.
  8. Ancillary Items: Products or services supporting the dominant service in the Services Plus File, and not sold on GSA Advantage! (ibid)

Questions about how to categorize your offerings? Give us a call.

SBA Halts New Applications for 8(a) Program: What You Need to Know

The Small Business Administration (SBA) has put a temporary hold on accepting new applications for the 8(a) small business program. This move comes in the aftermath of a significant court decision that found parts of the program unconstitutional. (Washington Technology August 21, 2003)

The crux of the matter lies in the SBA’s utilization of the “rebuttable presumption” process, which allowed many companies to be certified as small, disadvantaged businesses without substantiating their social disadvantage. However, a recent court case, involving Ultima Services, a non-8(a) company, challenged this process. The court ruled in favor of Ultima Services, asserting that the use of rebuttable presumption violated their Fifth Amendment rights. Consequently, the SBA has been compelled to halt the acceptance of new 8(a) program applications. (ibid)

If your company was certified through the rebuttable presumption process, there are specific actions you must take to continue in the 8(a) program. The newly released guidance requires affected businesses to submit a “Social Disadvantaged Narrative.” This narrative should encompass the identities forming the basis of your social disadvantage, detailed accounts of discriminatory incidents related to education, employment, or business history, including dates, locations, parties involved, conduct details, and motivations behind the bias or discrimination. You should also elucidate how these incidents impacted your business progression. (ibid)

Existing applicants can proceed with their applications, though additional information might be needed. For those already within the 8(a) program, the narrative submission is not obligatory if previously completed. (ibid)

SBA is closely collaborating with the Justice Department to chart the course ahead in response to this court decision. Despite the temporary suspension of new applications, the agency is working on directives for agencies to continue awarding contracts to 8(a) firms. (ibid)

Remember, this situation is evolving. A hearing on August 31st could bring about changes, and SBA’s forthcoming guidance for contract awards to 8(a) firms remains eagerly anticipated. Furthermore, it’s important to note that the court’s ruling doesn’t affect 8(a) firms owned by Alaska Native Corporations or tribally-owned entities. They can continue business as usual. (ibid)

Stay tuned for updates as this story unfolds, and ensure you’re up to speed on the latest developments in the 8(a) program landscape. Should you have questions concerning the newly released guidance requirements, give us a call.

Prohibited telcom equipment may cost you

The General Services Administration’s (GSA) Office of the Inspector General (OIG) published a new report highlighting GSA’s failure to address prohibited telecom items on its Multiple Award Schedule (MAS) contracts. The report states that this puts customers at risk of unauthorized surveillance by foreign adversaries. In 2017 and 2018, Congress passed laws prohibiting the procurement of certain telecom and video surveillance services from specific entities, with FAS responsible for ensuring compliance. However, the OIG report reveals that FAS’s reliance on contractor self-certifications and the Prohibited Products Robomod process is inadequate in preventing the inclusion of prohibited items on MAS contract price lists. (MerriTalk July 11,2023)

The report also identifies FAS’s shortcomings in taking sufficient action against contractors violating Federal Acquisition Regulation (FAR) restrictions, as well as the lack of a process to notify customer agencies about purchases of prohibited telecom items. Furthermore, FAS initially failed to comply with FAR requirements by not including subsidiaries and affiliates of named entities in their efforts to identify prohibited items on MAS contracts. To address these issues, the OIG has made five recommendations to FAS Commissioner Sonny Hashmi, including strengthening controls and implementing more stringent consequences for non-compliant contractors. (ibid)

This report from the GSA’s OIG follows the release of the Federal Communications Commission’s (FCC) “Covered List,” which prohibits the sale of telecom network equipment and services from certain China-based providers due to national security concerns. The FCC’s ban aims to safeguard the nation’s communications networks and enhance the security and resilience of the domestic supply chain. These efforts reflect the commitment of both agencies to protect national security and mitigate risks associated with unauthorized telecommunications equipment and services. (ibid)

Questions about prohibited telcom items? give us a call.