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Federal Contracting

Reforming the Reformers

Over the next few years, GSA will institute approximately 25 reforms to improve the federal marketplace, with a goal of easing the buying and selling process for all involved. (Federal Times, July 24, 2019)

Alan Thomas, the commissioner of GSA’s Federal Acquisition Service, has named the following four initiatives as ‘cornerstones,’ bound to the success of the other ‘stones’ around them:

  1. Developing an enterprise-wide contract writing system — provides the contracting workforce “a single, core system that stores all of our data and has a set of common business processes”
  2. Managing catalog data — changing how industry systems and processes are represented to buying agencies
  3. Consolidating the Multiple Award Schedule program — occurring as we write, the current 24 multiple award schedules are merging into a single Schedule.
  4. Instituting a commercial platform initiative — an online buying platform, much like Amazon, which will allow government purchasers to order products without a contracting process. (ibid)

Many other reforms will go into effect over time. Additionally, GSA is working to make smaller improvements that make contractors and customer agencies more aware of available tools. These tools should simplify the contracting process. (ibid)

Have questions about the reforms and how they will affect the current procurement process? Give us a call.

Guard Sale ;-(

If you’re experiencing difficulty with the crazy, required mass mod GSA just released for the Schedule 84 guard services SINs, we wanted you to know that we’re here to help! Didn’t know about the mod? Here are some of the more important details:
  • GSA is calling this a Terms and Conditions mod, but it’s really much much more. In some cases, it will involve a completely new pricelist.
  • The mass mod was released at the end of June; you have until 31 August to accept it, and 30 September to upload your new pricelist (meaning all changes must have been approved at least a week prior to that) to remain in contract compliance.
  • Collective Bargaining Agreements (CBAs) no longer hold precedence on pricing.
  • You will need to use the new, beta-version SAM website to obtain your Service Contract Act (SCA) pricing.
  • Contractors must use market pricing only (no more Commercial Pricelists), based on SCA.
  • Your Most Favored Customer (MFC) will now be based on the highest percentage of sales to a customer type (federal, state/local, commercial, etc.).
Yes, this is a big, bad mod. EZGSA is on top of it, and ready and willing to assist you in keeping your GSA Schedule compliant. Just give us a call at 301-913-5000, or email us at mbotello@ezgsa.com, so we can get right to work for you.

It All Comes Down to SAM

GSA is merging its current legacy sites into one system, beta.SAM (the System for Award Management). SAM (login at sam.gov), is the official government website for people who make, manage, and receive federal awards.

Contracting organizations across the federal government post notices on proposed actions valued at more than $25,000 to SAM. These notices, or “procurement opportunities,” include solicitations, pre-solicitations, and sole source justifications.. Anyone interested in doing business with the government can use SAM to learn about available opportunities at no charge. However, you’ll find a few surprises at the new SAM.

The new domain contains data that has been migrated from government legacy systems. It supports two distinct federal awards: acquisition and federal assistance. Transitioning in this manner offers a more efficient way to access all federal award information.

Once you peruse the site, the government welcomes your feedback. Original SAM sites will co-exist with beta.SAM.gov until they are retired. Once the original SAM.gov site has retired, the beta site will be renamed “SAM.gov.” (beta.sam.gov)

Another way to look at the ten online sites being merged into one:

sam-new-img
source:sam.beta.gov Learning Center
For instance, SAM officially replaces WDOL.gov (Here’s a quick start guide for wage determinations.) as well as Assistance Listings and CFDA.gov. Users of CFDA.gov will be required to manage their listings using a new user account. (beta.sam.gov)

Have questions about your login credentials? Questions on where to go to obtain “official” information? Did you register and no word back on your registration? Give us a call.

HHS Did What?

The Department of Health and Human Services Program Support Center (PSC) has decided to end assisted acquisition services. Some agencies under the PSC umbrella include: the Office of Personnel Management, the Office of Special counsel, the Environmental Protection Agency, and the Defense Department (DoD).  (DoD accounts for roughly $1 billion of the $1.4 billion total contract amount under the PSC.) (Federal News Network, July 22, 2019)

It appears HHS stopped offering assisted acquisition services in mid June, just as agencies are preparing for fourth quarter acquisitions. This likely includes the $150 million multiple-award contract PSC was about to award for EPA along with a number of “in-process” contracts for DoD. Additionally, any award for the prior four years must be moved to other agencies or absorbed by the “home” agency by September 20, 2020. (ibid)

So why exactly did HHS decide to stop its assisted acquisition services? In a memo to the civilian agency customers, they said they do not have the internal controls, policies, or procedures necessary. DoD customers received a comparable memo. (ibid)

Why now? Possibly due to the manner in which PSC has handled classified information for DoD and other agencies’ procurements through the self-certification process. The self-certification process is achieved through the DD-254 form. However, a recent audit found that PSC does not actually perform classified work. (ibid)

Unfortunately, this abrupt change is putting a burden on many agencies. Since the decision was made and will affect the fourth-quarter spending, agencies must now scramble to get other assisted acquisition service provider help. The decision also affects vendors, who spend time and money to bid on solicitations that must restart. And the question remains: will vendors lose work from existing contract awards that they bid on and won?

Roughly one-third of all federal spending occurs in the fourth quarter, with one-quarter of the spending in September. Administrators plan to meet with member companies, DoD ,and the Office of Federal Procurement Policy to arrive at  a game plan going forward. (Federal News Network, July 22, 2019)

Will this affect a bid you are working on or a recent contract award? If so, give us a call.

FAR Changes

With the end of the Fiscal Year looming, the push is on to exhaust agency budgets. In an effort to make acquisitions move through the process more quickly and smoothly, DOD, GSA, and NASA have issued an amendment to the Federal Acquisition Regulation (FAR). The amendment fine-tunes the  FAR and eliminates a step in the acquisition process. (Fedscoop, July 15, 2019)

Per the FAR, agencies were required to justify the best procurement approach when using GSA’s IT Schedule 70, Governmentwide Acquisition Contracts, or assisted acquisition solutions. As of June 5, the new FAR amendment allows agencies to skip that step. Agencies are now able to quickly find GSA IT category contracts and acquisition solutions. (ibid)

According to Bill Zielinski, assistant commissioner of GSA’s Federal Acquisition services office, agencies “can now identify and quickly use GSA IT Category contracts and acquisition solutions, especially as they embark on their end-of-year IT spending and acquisition efforts.” Zielinski feels the new change to the FAR reduces the administrative burden for agencies procuring through GSA’s IT Schedule 70 or through GWACs such as 8(a) STARS 2 and Alliant 2, as well as through assisted acquisition programs. (Federal Computer Week, July 15, 2019)

Curious about the new FAR language and how it affects your GSA schedule? Give us a call and we can review it with you.