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Contract management

Not an employee, not an Entity Administrator in SAM.gov

Effective March 6, 2023, only employees, officers, or board members within a company, may hold the Entity Administrator position. By making this change, GSA hopes to increase the level of security while ensuring that companies are controlling who may update their registration in SAM.gov. Service providers and/or consultants may continue managing entity registration, however, specific actions will be required. (gsa.gov|interact March 6, 2023)

Company registration updates require the relationship status of individuals to the company. If you are not a company employee, officer, or board member you will have the Data Entry role, not the Entity Administrator role. The Data Entry role allows you to register new entities, manage updates, and renew entity registrations, however, you may no longer manage user roles. If a company used an Entity Administrator Appointment Letter (notarized letter process) in the past, this is no longer an option for non-employees. (ibid)

If your current Entity Administrator is outside of your company, there are two ways to change your Entity Administrator role to a company employee, officer, or board member:

  1. Send an Entity Administrator Appointment Letter to the Federal Service Desk (FSD) appointing an administrator, or
  2. Ask your outside Entity Administrator to assign the role to an individual within your company prior to the next registration date, within SAM.gov. (ibid)

Companies that currently have an employee, officer, or board member as their Entity Administrator for SAM.gov are not affected by this change. If you are not certain, you can view roles assigned to individuals within your company by logging into SAM.gov and selecting “My Roles.” (ibid)

Questions about your Entity Administrator or SAM.gov? Give us a call.

New GSA requirement – attest to software safety

According to a recent GSA memo, software vendors will be required to ensure that only approved software is acquired and used by GSA. GSA plans to use a Cybersecurity and Infrastructure Security Agency form to collect the letters. The forms will be available in early June. (FEDSCOOP February 1, 2023)

The Cybersecurity and Infrastructure Security Agency (CISA), Chief Jen Easterly recently urged industry to take responsibility to ensure the safety of its products. The CISA Chief also recommended shareholders make sure c-suite executives are viewing cyber risk as a board-level issue. (ibid)

GSA is collecting the letters of attestation in an effort to implement a memo signed by the White House. The memo requires all federal agencies to verify that all distributed third-party IT software adheres to the National Institute of Standards and Technology (NIST) supply chain security requirements. (ibid)

The Federal Acquisition Council has under consideration, embedding the requirement for software providers to attest to the security of their products within the Federal Acquisition Regulation (FAR). (ibid)

According to the memo, “GSA’s acquisition regulations (GSAM 511.170(d)) require GSA’s Information Technology (IT) Office to approve new software before its use at GSA. To comply with Executive Order 14028 and OMB Memorandum M-22-18, which require federal agencies to only use software that complies with Government-specified secure software development practices, GSA IT will update its processes to approve software including requiring vendor attestations. GSA IT anticipates issuing an updated attestation process by June 12, 2023.” (Memorandum for the GSA Acquisition Workforce 1/11/23)

The memo also states, “Contractors providing GSA with a cloud-based solution are encouraged to work with the Federal Risk and Authorization Management Program (FedRAMP). The FedRAMP approval process will streamline the GSA IT Standards Process allowing for a timely contract start. GSA also anticipates that leveraging FedRAMP will ensure and streamline compliance with the requirements of OMB Memo M-22-18 in the future.” (ibid)

Have questions or need some guidance with your letter of attestation? Give us a call.

GSA and the Small Business Administration are teaming up!

GSA is partnering with the Small Business Administration (SBA) to increase 8(a) contracting opportunities. The partnership makes it virtually effortless for GSA customers to use the MAS program to access various solutions from 8(a) contractors. (BUY.GSA.GOV l Interact November 18, 2022)

Once the implementation is complete the PA provides these benefits:

  • Increased opportunities for 8(a) contractors, allowing these contractors competition in a safe set-aside environment.
  • Accessibility to 8(a) contractors and various socioeconomic contractors, thus allowing for a vast range of products and services.
  • Increased ordering flexibility under the MAS Program.
  • Streamlined acquisition processes, thus incentivizing agencies to use 8(a) solutions.
  • GSA and SBA standardized processes for reaching an agreement on acquisition strategies. (ibid)

GSA is looking at a spring 2023 implementation of the Partnership Agreement. (ibid)

Are you an 8(a) contractor or have questions concerning your 8(a) contractor status? Give us a call.

New Emissions Rule right around the corner

The White House proposed the Federal Supplier Climate Risks and Resilience Rule on November 10. With the new rule, larger Federal contractors will face new requirements to report data on their specific greenhouse gas emissions to protect the Federal Government’s supply chains from climate-related financial risks. (MeriTalk November 11, 2022)

According to the White House the rule, “would require major Federal Contractors to publicly disclose their greenhouse gas emission and climate-related financial risks and set science-based emissions reduction targets.” (ibid)

The White House said, “under the proposed rule, the largest suppliers including Federal contractors receiving more than $50 million in annual contracts would be required to publicly disclose specific Scope 1, Scope 2, and relevant categories of Scope 3 emissions, disclose climate-related financial risks and set science-based emissions reduction targets. Federal contractors with more than $7.5 million but less than $50 million in annual contracts would be required to report Scope 1 and Scope 2 emissions. All Federal contractors with less than $7.5 million in annual contracts would be exempt from the rule. Small businesses with over $7.5 million in annual contracts would only be required to report Scope 1 and Scope 2 emissions under the proposed rule.” These disclosures and rules help to contribute to President Biden’s Federal Sustainability Plan. (White House Fact Sheet November 10, 2022)

The types of emissions that require disclosure are direct emissions, indirect emissions from purchased energy, and indirect value chain emissions. (MeriTalk November 11, 2022)

The White House said, “the proposed rule leverages widely-adopted third-party standards and systems that many Federal contractors already use when disclosing their emissions and setting emissions reduction targets, including the DCP environmental reporting system, the Task Force on Climate-Related Financial Disclosures (TCFD) Recommendations, and the Science Based Targets Initiative (SBTi) criteria.” (ibid)

The proposed rule is issued through public comment by the Federal Acquisition Regulatory Council (FARC) and amends the Federal Acquisition Regulation (FAR). (ibid)

Questions concerning the new Emissions Rule and the reporting requirements? Give us a call.

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A Technology “Schedule” in the making

The Small Business Research program is in place for companies to use to develop state-of-the-art technologies. GSA is working to build a contract, much like the GSA Schedule platform, to give agencies access to these technologies. The idea is to shorten the time between a prototype of a new technology and the time it takes to get it to government users. (Washington Technology October 28, 2022)

Federal users lose out on many technologies because they never advance to phase two of the program. According to Jim Ghiloni, acting innovation sector director and IDIQ labs group manager at the General Services Administration (GSA), phase three becomes a challenge because it requires agencies to fund further development work to take advantage of new technology. Ghiloni recently said GSA is working on a government-wide contract vehicle that gives agencies access to these emerging technologies. (ibid)

Ghiloni is working on the business case to present to GSA while market research is ongoing. A draft solicitation is expected in the spring of 2023. Ghiloni plans for the vehicle to be in place by the fall of 2023. (ibid)

The plan is for the contract to look a lot like the GSA Schedule program. Here’s how it would work:

  • Companies finish phase two of an SBIR contract with technology ready to sell
  • Submit a proposal to get a spot on the vehicle
  • Market technology to government agencies (ibid)

All SBIR contracts have three phases. The first phase is developing proof of concept. The second phase is ongoing research and development to prove the technology is commercially viable. Phases one and two of an SBIR contract are funded by the SBIR program. For a company to move to phase three, an agency buyer is needed to commercially develop the technology. To date, this has been difficult because there has not been a mechanism for agencies to use to fund the third phase. (ibid)

Ghiloni hopes to make it easy for agencies to start taking advantage of emerging technologies while at the same time, drawing new entrants to the government marketplace. (ibid)

Is your small business developing an emerging or new technology? Give us a call.