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Contract management

Oh 72a, We Hardly Knew Ya

You’re used to it, right? So it’s time to change! As of July 2019, the FAS Sales Reporting Portal (SRP) replaces our familiar  72A reporting system for GSA Schedule sales and Industrial Funding Fees (IFF) remission. Terms and conditions remain the same. And if you have an active claim, your contract will be held in the 72A system for now. (GSA Interact, March 18, 2019)

A three-step process directly impacts when and where a company reports sales over the next two reporting periods as well as the migration of historical data. The three steps are as follows:

Step 1: Reporting April 2019 sales and remittance of any IFF in the 72A System

  • When: April 1, 2019, through April 30, 2019
  • Contractor Action: Companies are now in the reporting period that covers January 2019 through March 2019. This is the last time companies will report sales and remit IFF, in the legacy 72A System. After this cycle, all reporting will take place in the FAS Sales Reporting Portal.
  • Change: None. There is no change to the current reporting process for FY19 Q2 reporting.
  • Impact: This will be the final time companies report in 72A and all future reporting will be in the FAS SRP. (ibid)

Step 2: Transition to the FAS Sales Reporting Portal

  • When: Starting May 1, 2019
  • Contractor Action: Contracts will be visible in the new system as of May 1, 2019. At that time, go to the FAS SRP website and register for the required multi-factor authentication process. Anyone listed on a contract as an IFF POC, Contract Administrator, or Authorized Negotiator can register for access into FAS SRP. (Access to the portal does not require digital certification.) Registration to the portal begins May 1, 2019, and runs through the first time a company reports sales in the FAS SRP.
  • Change: Contracts will be moved to the FAS Sales Reporting Portal (SRP).
  • Impact: Effective July 2019, companies will report all sales and remit any owed IFF in the FAS SRP, covering the reporting period from April 2019 through June 2019. (ibid)

Step 3: migration of Historical Data from 72A to the FAS SRP System

  • Contractor Action: None
  • Change: Once April 2019 sales and IFF are reported into the 72A System, GSA is migrating all historical sales and payment record into the FAS SRP.
  • Impact: All historical records will be held in the FAS SRP. This will be maintained for the life of the contract. (ibid)

Note: Sales adjustments will no longer be allowed in 72A after April 1, 2019. (ibid)

Not so onerous, really, but we understand you may have questions. Please feel free to call us at 301-913-5000.

Are you practicing “safe cybersecurity”?

The Department of Defense (DoD) is working to extend its own cybersecurity expertise and infrastructure to small and medium-sized businesses. Their current plan is to build a “secure cloud” for company data instead of leaving it to the responsibility of the contractor. (Federal News Network, March 25, 2019)

DoD plans to use their 2020 research and development budget for the Defense Industrial Base (DIB) Secure Cloud Managed Services Pilot. The project will start by making the cloud service available to a specified number of small and medium companies that support prioritized, critical DoD missions/programs. (ibid)

Ellen Lord, the undersecretary for acquisition and sustainment said, “In contract terms, the Department would treat the secure cloud as Government Furnished Equipment (GFE).” She believes larger companies are already quite savvy and have the funds to create a hardened environment. Ms. Lord is most concerned with small, innovative companies. She said, “we sit down and talk to them about cybersecurity, and sometimes we hear – no kidding, ‘my nephew does my cybersecurity.’ That gets us a little bit worried. And we know that we will either put these small companies out of business, or we will drive them away from the Department of Defense if we give them very, very onerous regulations to meet.” (ibid)

In 2017 DoD began inserting clauses into contracts that require firms to implement the security controls in NIST Special Publication 800-171. Prime contractors are required to impose the same requirements on their subcontractors as they are expected to meet when coming in contact with sensitive, unclassified information. (ibid)

It does not appear as though verification of a company’s compliance with the standards has been accomplished, thus far. However, going forward, spot checks are likely to take place with the hope of getting to a point where DoD certifies third-party cybersecurity examiners to help verify contractors systems meet the existing requirements and that their systems are adequately protected. Currently, about 800,000 systems should be regularly audited. (ibid)

We do know that information is being stolen; but classification levels make it hard to investigate in a reasonable time frame. The details of any individual data theft are classified, making specifics about nature and volume difficult to determine. We also know that sufficient cybersecurity capabilities to protect information must be in place sooner rather than later in order for small and medium-sized businesses to remain contractors to DoD.

Call us with any questions regarding this project at 301-913-5000.

 

 

 

 

Time For a Facelift

All businesses contracting with the U.S. government must obtain a Data Universal Numbering System (DUNS) number. The DUNS number system, managed by Dun & Bradstreet since 1962, was opened to competitive bidding last year and has since been awarded to Ernst & Young.  (Nextgov, March 2019)

The award is for a one-year base period with four one-year options, making the contract total worth $41.8 million if all options are exercised. (ibid)

Over the next few months, the DUNS will be phased out and replaced by the System for Award Management Managed Identifier or SAMMI number. GSA is working on the standards for the new system with an interagency working group. (ibid)

With the new entity validation service, users provide their registration information at SAM.gov and that information is validated against the Ernst & Young data, with no charge to the contractor. The government has unlimited rights to the data in perpetuity. Besides having a safe and secure method for validating entities, the process will be simplified for those seeking contract awards. In addition, the new system will create a workaround for the proprietary nature of the validation services, which have been viewed by many as monopolistic. (ibid)

Have questions about the new validation service? Give us a call at 301-913-5000 and we can explain it.

 

Small Businesses, Come on Down!

The Centers of Excellence, established in 2017 by GSA and the White House Office of American Innovation, work with agencies to develop IT modernization plans. So far, two agencies are on board: the Department of Agriculture is in the second and last phase of the program and the Department of Housing and Urban Development is planning a September start. (Nextgov, March 12, 2019)

During the first year of the program, Agriculture completed Phase I and entered Phase II, prior to HUD’s start beginning work on phase I. The pace should pick up this year with many agencies, under a new BPA, working through Phase I at the same time, according to program Director Bob DeLuca, although no start-up date has been made available. (ibid)

It’s expected the program’s next generation will include the original five centers, focused on cloud adoption, contact center, customer experience, data analytics, and infrastructure optimization. Two additional centers for change management and information security will be added. GSA is adding the change management piece to keep things running smoothly once GSA leads step out of the picture. (ibid)

A blanket purchase agreement released last Tuesday outlined the program’s next iteration. This BPA adds new functional areas and points to the future procurement strategy. It will last three years from the award date with an expected value of $100 million, which can increase without mods. (ibid)

Two phases will continue to exist in the updated program: a discovery phase, wherein an agency works with the relevant centers to assess the current situation and devise a plan; and an implementation phase. The new BPA will cover the first phase only, with the second phase of work contracted separately. (ibid)

The final RFQ has been created to attract more small businesses to the program. Vendors can bid on as many or as few of the functional areas as they choose. (ibid)

Prospective bidders must hold GSA Schedule 70 contracts for the relevant special item numbers listed in the RFQ. The turnaround time for the entire RFQ process is short to test how companies respond during short cycles. (ibid)

Vendors interested in bidding will have to complete four submissions: a set of challenge questions, a list of potential scenarios, a technical and management approach description, and a pricing sheet. The challenge questions will be available through Google Forms starting 28 March. (ibid)

Vendors will also be responding to the scenario through a Google Form, answering the question: How would you obtain agency wide buy-in for the modernization efforts promoted by the CoE while also linking efforts and fostering collaboration with other vendors and government staff across all of the centers at the agency partner? (ibid)

Instructions for the other submissions are included in the RFQ. The entire package is due by noon on April 1.

Are you interested in bidding or learning more about the BPA? Call us at 301-913-5000, and we can walk you through the submission requirements.

Schedule 736 hits the refresh button

It’s happening again. Any comments concerning the refresh must be submitted by March 26th, 10 business days after the official notification of the refresh was announced. (GSA Interact)

The updates for GSA Region 2, enhancing schedule 736 Temporary Administrative and Professional Staffing (TAPS), are as follows:

(a) Time limit on use of temporary help service firm.  An agency may use a temporary help service firm(s) in a single situation, as defined in § 300.503, initially for no more than 120 workdays. Provided the situation continues to exist beyond the initial 120 workdays, the agency may extend its use of temporary help services up to the maximum limit of 240 workdays.

  • SIN descriptions have been simplified and classified according to major Occupational Classes. A link under each SIN provides access to the SCA Directory.
  • New pricing templates to simplify price proposals. These vendor pricelists distinguish between Wage Grade labor rates and Professional labor rates.
  • Additional NAICS secondary codes have been added to identify major sub-categories such as Court Reporting. (ibid)

None of these changes require modification to contracts or change the original contract scope. GSA says this refresh helps to make the Schedule more clearly comprehensible for industry partners and agencies. Vendors may update their price lists as necessary. (ibid)

GSA has also announced a webinar to review the Schedule 736 changes, for Wednesday, March 27th, 3:00 PM EST. Access the webinar on the following link:meet.google.com/doo-extp-yck(ibid)

If you’re not certain about how your contract is affected by this refresh, give us a call at 301-913-5000, and we will help.