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Small Business

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.

STARS in Your Eyes?

After spending more than $1.6 billion on STARS 2 in 2018, GSA is constructing the third version of the 8(a) government-wide Streamlined Technology Acquisition Resource for services or better known as STARS. The third draft solicitation focuses on IT services. Those services include:

  • Software Development
  • Software Maintenance
  • Emerging Technology such as artificial intelligence (AI)

STARS 3 will be an eight-year contract, with a $20 billion ceiling. All responses to the draft RFP are due September 6, 2019. (Federal News Network, August 12, 2019)

Have questions concerning the STARS 3 draft RFP? Give us a call.

Setting Aside the Small Biz Set Asides

The National Background Investigations Bureau (NBIB) is moving from the Office of Personnel Management to the Department of Defense (DoD), merging with the Defense Counterintelligence and Security Agency (DCSA). Of interest to many of EZGSA clients, sources say the move anticipates plans to significantly diminish small business goals at the agency from 65 percent to 10 percent, according to Elizabeth Mudd, small business program manager. (Defense Systems, August 7, 2019)

Mudd believes that the whopping decline in small business goals intends to promote more subcontracting to supplement the four primes that oversee background investigation services. While this may be true, the bottom lines remains that in this fiscal year, NBIB is contributing about $804 million in small business eligible dollars compared to DCSA’s $73.4 million. (ibid)  Maybe the merger won’t actually change the dollar amount contracted with small businesses in the long run, but we’re not holding our breath.

Want to gripe or discuss strategy? We’re here.

Scrubbing the FAR

The Federal Register Publications requests comments on the following three proposed Federal Acquisition Regulation (FAR) rules:

  1. FAR Case 2015-002 – the rule proposes to amend the FAR to require electronic submission of DD Form 254, Contract Security Classification Specification. This form is used to communicate security requirements to contractors when the performance of contract requirements requires access to classified information and the form acts to automate processes and workflows. (This form is also used by prime contractors to communicate in the same manner to subcontractors.) Comments should be submitted by September 10, 2019, via the Federal eRulemaking portal. (Acquisition.gov)
  2. FAR Case 2018-007 – the rule proposes to amend the FAR  by revising thresholds subject to inflation adjustments so that the periodic inflation adjustments will apply to existing contracts and subcontracts that contain the revised clauses. The next rule raising thresholds for inflation is planned to go into effect, October 2020. Comments are due by August 23rd, via the Federal eRulemaking portal. (Acquisition.gov)
  3. FAR Case 2018-003 – the rule proposed by NASA, GSA, and DOD is to amend the FAR to implement section 1614 of the National Defense Authorization Act for the Fiscal year 2014 and regulatory changes made by the Small Business Administration (SBA). (Section 1614 addresses credit for lower-tier small business subcontracting.) (ibid) 

Additionally, the following are up for review.

  • Section 1614 of the NDAA for FY 2014 amended the Small Business Act when a prime contractor has an individual subcontracting plan for a contract with a single executive agency, the prime contractor receives credit towards its subcontracting goals for awards made to small business concerns at any tier by subcontractors with individual subcontracting plans. Additionally,  section 1614 provides new assurances for offerors relating to activities to be performed by the contractor to monitor the performance of subcontractors subcontracting plans, and by subcontractors to monitor the performance of their subcontractors subcontracting plans. Section 1614 requires the contractor to demonstrate procedures established to ensure subcontractors at all tiers comply with their subcontracting plans. Section 1614 also revised the definition of “subcontract” in the Small Business Act. (Acquisition.gov)
  • Per SBA’s final rule, the prime contractor’s performance under an individual subcontracting plan will be evaluated based on its combined performance under the first-tier and lower-tier goals. Additionally, the final rule implements the statutory requirements related to the new assurances and written statement to be included in subcontracting plans. Comments are due by August 26th via the Federal eRulemaking portal. (regulations.gov)

Working through how these FAR changes will affect your current contract, or future bidding/contracts? Give us a call and we can explain.

COMET Commeth!

The General Services Administration (GSA) has released the second and much sought after piece of the IT services procurement known as COMET. The solicitation aims to create a multiple-award blanket purchase agreement (BPA) on top of IT schedule 70.

GSA plans to make between 10 and 12 awards with a minimum of 25 percent set aside for small businesses. The BPA will require a host of IT services, including operations and maintenance, cloud and the continued development, and support of the acquisition systems portal beta.SAM.gov. GSA’s goal is a three-step evaluation approach, including an in-person technical challenge.

In April, GSA issued the RFP for the first and substantially smaller piece of COMET focused on architecture, engineering, and advisory support. (FedBizOpps)

Have questions about COMET and how your company fits in? Give us a call at 301-913-5000.