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Federal Contracting

CMMC in GWACs

GSA is expected to begin applying the Department of Defense’s Cyber Maturity Model Certification (CMMC) at the order level to governmentwide acquisition contract vehicles. (Govconwire, November 10, 2020)

According to Keith Nakasone, deputy assistant commissioner for acquisition in the General Services Administration Office of IT, future Government Wide Acquisition Contracts (GWACs) will include CMMC requirements, layered in over time. In this video interview, Nakasone explains that the requirements are being added to make sure contracts are within scope for the Department of Defense, the largest GWAC customer. (Government Matters, November 8, 2020)

Nakasone hopes to educate and train industry partners on the CMMC requirements over time. Although he didn’t state outright that CMMC will become part of all future contracts, they are part of the Polaris draft RFP, scheduled for release in December. (ibid)

Need assistance in understanding the CMMC requirements? Give us a call.

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.

New and Improved CPARS. When?

The Office of Federal Procurement Policy recently conducted a survey with a host of agencies regarding contractor performance assessment ratings (CPARs) and if they are completed at all, they are not on time.  (Federal News Network, October 5, 2020)

Working with GovConRx, OFPP found 95 percent of respondents would actually like to take part in contractor self-assessments at agreed-upon intervals throughout the contract performance period. A majority of respondents (84 percent) support a “CPARs Lite” perspective for certain fixed price and commercial item contracts as well as CPARS ratings demonstrating specific objectives and contract outcomes. It appears many agencies are doing their “own thing” right now; for instance, OFPP and DHS have launched pilot programs using artificial intelligence to gather data and complete the ratings. VA also has its own program to review key performance indicators.(ibid)

What does all this mean? Changes to CPARs is necessary and on the horizon. Unfortunately, there is still no timeframe for how soon we will see them.

Questions about CPARs and how they might work to help you with future procurement efforts? Give us a call.

DoD and Software

The Department of Defense is updating its purchasing policies for software acquisition, moving toward an  Adaptive Acquisition Framework. (fedscoop, October 7, 2020)

DoD’s new software purchasing policy includes some big changes: its focus will be on updating software on an “as needed” basis instead of custom coding. In the old model DoD purchased software in the same manner as it bought tanks, which often took years. The new policy, titled 5000.87, allows contracting officers to have the tools they need to buy code while giving them the flexibility to focus on the development and maintenance of programs. (ibid)

According to a DoD spokesperson, “as more parts of the military use similar technology-development stacks, achieving Authorities to Operate (ATOs) will happen much faster.” The goal is to improve cycle time which should now be achieved with the new framework in place.

Are you looking to work with DoD to provide software or code and have questions about how to get started under the new purchasing policy? 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.