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GSA Schedule contract

GSA contracting just got a whole lot easier – well, maybe

This past May, the General Services (GSA) issued Refresh #6 to the Multiple Award Schedule (MAS) Program solicitation. The goal of Refresh #6 is to modernize and simplify the way contractors do business with the Federal Government. (SecurityInfowatch.com June 14, 2021)

Some of the most significant changes are:

  • Establishment of a Verified Products Portal (VPP). The VPP aims to keep vendors from unauthorized selling of products to the government, under the Federal Supply Schedule.  In most cases, manufacturers who did provide a Letter of Supply (LOS) to resellers will use the VPP as an alternative authorization. (The VPP will not replace GSA Advantage or the SIP program, see VP*@*sa.gov)
  • COVID-19 Waiver which creates a temporary waiver for some requirements of the GSA submission application for vendors who offer products or services supporting the government’s response to COVID-19. The two-year corporate experience requirement is waived.
  • MAS contract cancellation deferrals. This is extremely helpful to contractors who haven’t met the minimum sales requirements per the I-FSS-639 Contract Sales Criteria.
  • Consolidation of the GSA Schedules Program. GSA, by consolidating, hopes to eliminate duplication and standardize processes while at the same time updating terms and conditions. The original 25 GSA Schedules became one, with 12 large categories and 83 subcategories. Contractors may now add new SINs beyond their legacy SINs previously awarded. Current GSA contractors had their awarded SINs mapped to new SINs that correspond to NAICS Codes. (All integrators and contractors are advised to speak with their Contracting Officer to figure out the next steps for SINs from a different large category.)
  • Order Level Materials (OLM) SIN added across all categories. OLMs are acquired at the order level giving the contracting officer (OCO) responsibility for making a fair and reasonable price determination. OLMs are authorized for use in direct support of another awarded SIN, they are not Open Market Items.
  • Phase III of the MAS Consolidation requiring all current contractors to consolidate their contracts under one unique identifier  – Dunn & Bradstreet number. This gives contractors a single point of contact within GSA. GSA provides Modification Guidance with each refresh. Contractors should register for the GSA FAS ID and keep passwords up to date.
  • Unique Entity Identifier (UEI) will be issued to contractors in early 2022. This identifier will eliminate the usage of the Dunn & Bradstreet number as a contractor’s government identity. For contractors registered in SAM.gov, the process will take place automatically. (ibid)

GSA is making some major changes over the next 12 months to their GSA Schedules Program. However, the Cybersecurity Maturity Model Certification (CMMC) is not expected to be included in the MAS solicitation. Agency-specific requirements for technical certification will be outlined in each specific request for quotation. (ibid)

Are any or all of the above changes a little confusing? Give us a call.

 

 

 

Small business and startups are front and center

Boosting small businesses and software for DoD are priorities for the Biden administration and their nomination for the Defense Department’s technology efforts.  Heidi Shyu, nominated for undersecretary of defense,  recently introduced her priorities to modernize the military during her confirmation hearing. She stated, “In order to rapidly transition the latest software, we need to have an open architecture that isolates the software from the hardware then allows rapid user testing.” (Defense Systems May 26, 2021)

Shyu told the senate that DOD should be investing so that development and procurement are 70% of their costs for a new weapons system. Shyu proposed buying more emerging tech such as artificial intelligence, synthetic biology and hypersonics rather than investing in older systems. Shyu said, “today, sustainment makes up 70% of total weapon system cost, with development and procurement making up 30%.” (ibid)

During Shyu’s hearing, she mentioned small businesses, especially startups working on new technologies, repeatedly. Shyu feels they are necessary for the Defense Department’s success. Shyu did not lose sight of the inability of the acquisition system to shift prototypes into programs. Shyu plans to institute a clear transition path. (ibid)

Shyu said, “part of the reason there is a valley of death for technology is that a lot of the technology programs are being developed by small companies, and unless you had the foresight two years ago to understand that the technology is going to be mature within two years time, by the time you get the money to buy that technology it’s two years old now.” (ibid)

Shyu said, “I saw a six-person company that’s developed any type of fuel as input and the output is a DC-plug. Those are the types of creative, innovative companies we need to nurture. And they are struggling to figure out who to talk to in the DOD.” (ibid)

Are you an innovator or a small business looking to work with the Department of Defense? Give us a call.

 

 

 

 

Procurement vs. Purchase

If we can be certain of one thing, it is that the pandemic wreaked havoc on many businesses and their business models. We tend to see government procurement growth during times of crisis. Once the media blasted us with headlines of medical device and personal protective equipment shortages, procurement officials found themselves in a precarious position. How to get supplies and get them fast.

Rick Grimm, chief executive officer of NIGP, the Institute of Public Procurement worries that procurements may slow down, now that shortages are being met. According to a brief from NIGP, “when skilled, professional procurement is buried within an organization and disconnected from the decision-making process, key business opportunities efficiencies and full value for money may be lost.” (Route Fifty May 7, 2021)

We witness the word “purchasing”  being substituted for the more comprehensive term “procurement.” Many believe this field should cover a broad scope of activities such as developing suppliers, strategizing to enhance supplier relationships, actively managing acquisitions and supervising contracts, and evaluating supplier performance. (ibid)

State governments made great inroads with suppliers during the pandemic. Many incentivized the private sector. In Maryland, where weapons systems are made for the Department of Defense, producers pivoted to make ventilators. Hand sanitizers were also retooled and made locally. (ibid)

The challenge to governments was understanding how vendors could best be utilized. There was no way to work with overseas manufacturers. Local product lines were evaluated and swiftly shifted. (ibid)

What does the future hold? Hopefully, the speed of procurement progress over the past year will not be in vain. Grim stated, “leveraging the value of procurement in achieving the government’s mission, helps you achieve those goals and becomes procurement’s mission as well. The big challenge, still, is getting the bosses of procurement to understand its strategic value.”(ibid)

Ready to get into federal procurement? Give us a call.

 

 

GSA is going green!

GSA is off and running to make the May 27, White House deadline to deliver a plan around clean energy vehicles and green electricity. According to the executive order, GSA must deliver a plan to address clean energy vehicles and green electricity. (Federal News Network, April 28, 2021)

Sonal Kemkar Larsen, the senior adviser to the GSA administrator on climate said, “one thing that is really important to us at GSA across the board is to be looking at how we can decarbonize our entire supply chain. We procure a lot of different things: Energy, buildings, government goods, and vehicles. In all of those, we need to look at our supply chains, the manufacturers, the businesses we are working with all the way to the design and installation in all of this. There is carbon from the beginning to the end so decarbonization is going to be a big lift as we look across the supply chain. A new focus for us is to look across all aspects of procurement.” (ibid)

Under the order, GSA must address how it will attain:

  • A carbon pollution-free electricity sector by 2035
  • Clean/zero-emission vehicles for federal, state, local, and tribal government fleets, including Postal Service vehicles
  • Additional legislation required to accomplish these objectives
  • Certifying the U.S. retains the union jobs integral to and involved in managing and maintaining clean and zero-emission fleets while adding union jobs in the manufacture of the clean fleets (ibid)

Katy Kale, the acting GSA administrator, said the Federal Green Building Advisory Committee created two new task forces – the environmental justice and equity task group and the federal building decarbonization task group. (ibid)

According to Kale, “the decarbonization task group will explore opportunities for reducing greenhouse gas emission in buildings in the federal real estate portfolio through the use of renewable energy, energy efficiency, electrification, and smart building technologies. They will provide some recommendations to GSA this fall so we can begin to develop a roadmap for the decarbonization of federal buildings. The environmental justice and equity task group will improve engagement with diverse communities and key partners throughout the design, construction, operations, renewal, and occupancy. We believe this engagement will lead to increased inclusion, opportunities, and green jobs in the federal sustainability building process.” (ibid)

Kale went on to say, “when we are talking about decarbonization in building, it’s all of the things that we need to do to reduce and eliminate greenhouse gas emissions that are caused by the operation of the building. That could include replacing gas boilers with solar hot water or using ground source heat pumps. Really we need to make sure we are including every efficiency measure that we can, including using smaller, more local equipment for heating and cooling, making sure motors are high-efficiency motors, adjusting control strategies to reduce peak loads. It’s A to Z, we’ve got everything covered.” This is quite a large opportunity for GSA as 60% of its leases held are going to expire between fiscal 2019 through 2023. (ibid)

The other area of “green” opportunity for GSA is through the vehicles it manages. GSA owns and manages over 670,000 cars and trucks and manages more than 200,000 leased vehicles. As of today, GSA has a fleet of 16 types of battery-operated vehicles and 5 plug-in electric vehicles. (ibid)

According to Charlotte Phelan, the assistant commissioner of the Office of Travel, Transportation, and Logistics in the Federal Acquisition Service (FAS), “the biggest challenge that we are looking at is actually the charging infrastructure. We need to deploy electric vehicle infrastructure to make sure we are able to do large-scale vehicle deployment while also ensuring agencies are able to accomplish their mission.” Phelan expects a plan to address the charging infrastructure to be out in the coming months. (ibid)

According to Sonny Hashmi, the commissioner of the FAS, the goal is to get to zero emissions.

Are you looking to be part of GSA’s mission to decarbonize its supply chain? Give us a call.

 

 

Not everyone is sold on the Transactional Data Reporting (TDR) pilot

Almost five years ago GSA launched the Transactional Data Reporting (TDR) pilot to replace the Price Reduction Clause (PRC). GSA’s goal is to use the data received, to obtain better pricing from contractors. GSA calls TDR a success, critics are not so quick to agree. (Federal News Network May 10, 2021)

Jeff Koses, GSA’s senior procurement executive said, “GSA has successfully demonstrated the value of TDR under the existing scope of the pilot. It has shown steady progress over the past four years, met most of the pilot’s objectives in the most recent year, and has made the necessary investments to leverage TDR’s potential in the years to come. We will continue to make improvements, especially in contracting officer usage.” However, Koses made no mention of using the TDR information in 2019 or 2020 (ibid).

Some argue that TDR works on paper, but not in reality. Many contracting officers are reluctant to use the data for decision-making. One industry expert went so far as to say, “I have not experienced any negotiations based on TDR data in order to form an opinion.” Others have suggested that the data is incomplete and that GSA has no strategy to back the pilot. (ibid)

One consultant pointed out that as more companies participate in TDR, the IG’s ability to audit prices before an award is made is more difficult. She noted, “under the TDR pilot, the population of auditable contracts has ostensibly been cut in half. When you remove the major resellers and the integrators, what remains are largely professional service contractors and products companies under Schedules 84 (Law Enforcement), 71 (Furniture), and 66 (Scientific). The audit threshold for annual sales is also reduced due to the smaller pool of contracts from which the OIG is selecting. Small businesses who would never have been a blip on the OIG’s radar are now at much higher risk of pre-award audit.” (ibid)

Another complication is GSA’s move toward unpriced contracts under Section 876 of the 2018 National Defense Authorization Act. The Act makes the Price Reduction Clause as well as TDR less necessary because the burden is on vendors to provide the lowest price possible as part of contract negotiations. (ibid)

Koses said GSA will refine and consider:

  • The ability of Federal Supply Schedule contracting officers to use transactional data for price negotiations in lieu of commercial sales practices and price reduction clause disclosures
  • The impact of an expanded data collection on GSA’s ability to use the data it currently collects
  • The impact on current/future GSA schedule contract holders
  • Communication to industry partners
  • Training and tools for category managers not impacted by TDR
  • Possible impacts on other FAS initiatives such as the National Defense Authorization Act (ibid)

So when will the pilot move to production? The waters remain murky. Whether the IG will move from the production stage should be made more clear when the Inspector General report on the TDR pilot is released, in the coming weeks. Vendors should be ready to invest in systems to collect and report pricing data, should the TDR pilot go into production.

Questions concerning how to collect and report pricing data? Give us a call.