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Schedule 70

Specs of the New IT Large Category

In GSA’s new Consolidated Schedule, Information Technology comprises one of the twelve large categories under which you can hold products and services. This large category has seven subcategories, including the following:

  • electronic commerce
  • IT hardware
  • IT services
  • IT software
  • IT solutions
  • IT training
  • telecommunications

Former SINs 132-33 and 132-34 now fall under NAICS code 511210, software licenses. Also, 132-54 and 132-55 now use code 517410, commercial satellite communications solutions (COMSATCOM).

If you submitted a FastLane proposal to IT in the past month or so, it has been put on hold until January 2020.

Dun(s) Dun Dun Dun … No More

After almost 60 years of utilizing a DUNs number, every organization doing business with the government will receive a new identification number. Beginning in December 2020, the number and the process to acquire the Unique Entity Identifier (UEI) will change. The new identifier will be generated through SAM.gov; however, DUNS numbers will be retained for historical purposes and Dunn & Bradstreet open data limitations remain in effect in perpetuity.

GSA is moving to a new, non-proprietary identifier, a 12 character alpha-numeric value, will be assigned by the System for Award Management. The Federal Register announced the new (UEI), including the identifier standards. Additional updates to the UEI can be found here: gsa.gov/entityid. (GSA.gov Unique Entity Identifier Update, September 9, 2019)

As you can imagine, many questions surround the upcoming change, and GSA’s recent online meeting answered some of them. Those that missed the meeting or want to listen again can find the presentation at beta.SAM.gov  and selecting the UEI video link. All questions submitted and answers provided are also available on this downloadable pdf.

The transition phase began in July of 2019, but DUNS will continue as the official identifier until December 2020. During the transition, all existing entity registrations will automatically be assigned a new UEI which will be displayed in SAM.gov and no one will be required to re-enter this data. (ibid)

Thinking this small change can lead to a lot of confusion? Have some questions that didn’t get asked or answered during the GSA public meeting? Give us a call.

Refurbishing Fraud

Yeow! GSA will be removing refurbished technology from the Schedules as part of the upcoming consolidation. We can thank cybercriminals for this lovely change.

Individuals not associated with the government have been placing IT orders. They trick small businesses into sending used hardware to empty warehouses, where they remove the equipment and sell it on the black market. Meanwhile, they never pay the original bill.

Additionally, some of the equipment has been discovered as counterfeit — which of course doesn’t meet government standards — as refurbished. This leaves the purchasing agencies open to risk. (FEDSCOOP, August 21, 2019)

According to Lawrence Hale, a director within the GSA Federal Acquisition Service, fraudsters phish small businesses, and GSA cannot guarantee the origin of refurbished products. “It’s a supply chain attack.” The only way to stop it is to shut the SIN down. (ibid)

As GSA consolidates 24 of its Multiple Award Schedules into one on October 1, 2019, a request for information is looking for industry feedback on supply and service categories and SINs that the forthcoming solicitation will be split into. (ibid)

Do you resell refurbished technology equipment to the government? Are you wondering how to provide feedback on the removal of SIN 132-9, allowing for the purchase of refurbished technology?  Give us a call.

TDR Pilot Still Flying

GSA is extending the Transactional Data Reporting (TDR) pilot program for an additional year, giving everyone ample time to work on the pilot while preparing for the upcoming Schedule consolidation.  The TDR pilot program collects pricing data, including cost to the government for services and products sold under GSA contracts. Ultimately, TDR will replace GSA’s Commercial Sales Practices. (Federal Computer Week, August 19, 2019)

TDR was implemented as a noncompulsory, three-year pilot that included eight schedules and their associated SINs. GSA created TDR to reduce bureaucratic burden and increase transparency by requiring monthly reporting of transactional sales data from government-wide contracts, including Multiple Award Schedules contracts. Ultimately, TDR promotes smarter purchasing by federal agencies by allowing expedited and more comprehensive data to assure best value. (ibid)

The GSA Office of Inspector General (OIG) issued a report last summer pointing out that the TDR pilot will not produce a quantifiable measurement. According to the OIG, data is not available for use and there are no performance targets. The IG asked GSA to set performance targets for each metric used and to verify the data is available and valid. (ibid) GSA and the FAS Commissioner Alan Thomas stated that the pilot was just getting ramped up and that some tweaks might be necessary based on the OIG report. However, the extension to the TDR pilot will allow more time for additional data gathering. According to Roger Waldron, president for the Coalition for Government Procurement, the extra time will give the pilot stability while allowing the price reductions clause to be removed. (ibid)

GSA will review the pilot at the end of fiscal year 2020 and at that time determine whether to cancel or expand the program to all GSA Schedule SINs. (ibid)

Still wondering how you can take part in the TDR pilot or how GSAs multiple schedule consolidation might work in your favor? 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.