Just the Facts FAS, Please

Earlier this week, a GSA watchdog discovered erroneous reporting of small business contracts by the Federal Acquisition Service (FAS). (Government Executive September 17, 2020)

The General Service Administration (GSA) inspector general (IG) recently provided a report that focused on the data entered into the Federal Procurement Data System – Next Generation, which is managed by GSA. The Small Business Administration (SBA) uses the system data provided to determine if the federal government is achieving its annual goal of awarding 23 percent of contracts to small businesses. An IG review of FAS procurements from fiscal 2016 and 2017 and shows that small business procurements have been grossly overstated.

“We found that FAS’s reporting of small business procurements contained significant inaccuracies. We identified $89 million in procurements erroneously recorded as small business in the Federal Procurement Data System – Next Generation. Additionally, FAS’ small business procurement reporting does not identify the extent of the work performed by large businesses. We found approximately $120 million of small business procurements in which large businesses performed a portion of the work.” (ibid)

After interviewing small business contractors and GSA officials as well as analyzing agency contracting data, the IG determined many of the issues to be out of GSA’s control. For instance, the IG found that classification codes¬† often “pre-populate” for task orders; due to the nature of the software, officers cannot override the system to update the task order codes. In addition, no mandate exists for FAS or small businesses to report how much of the work completed on a contract is subcontracted to large businesses. This leads to inaccuracies when assessing FAS’s small business procurements. Many believe the inaccuracies will never be fully fixed due to the competing policy issues and marketplace anomalies. (ibid)

The IG recommended the following:

  • Fix the limitations of the contracting system to enable accurate reporting
  • SBA and the commissioner discuss how subcontracting and reseller agreements are reported

How does this affect your contract or an upcoming proposal? Give us a call.

Is it Beta, Old, or New SAM?

Over time, GSA is transitioning reporting tools to beta.SAM, while the original SAM.gov remains live. Although the final site will also be called SAM.gov, it will be much different than the current one. When the full functionality of the new SAM.gov is moved over to beta.SAM, the latter will lose the “beta” prefix and the old SAM.gov will simultaneously be retired. Confused yet? (Nextgov September 11, 2020)

According to Judith Zawasky, assistant commissioner for the office of systems management in the Federal Acquisition Service (and former EZGSA employee!), “the new site is on track to lose its “beta” designation in 2021.” Zawasky is trying to ensure that remaining transition areas and training are smooth. The soft launch is expected to be finished by 17 October, and after that date, users will no longer be able to run reports on the FPDS.gov site. Searches will remain part of the site for a slightly extended period.¬†Zawastsky noted that what remains of the transition to the new SAM.gov may not be completed before 2025. (ibid)

The final SAM.gov site will include FBO, under Contract Opportunities; FPDS, under Data Bank; the original SAM.gov; the grants site Catalog of Federal Domestic Assistance, CFDA; Wage Determinations Online, WDOL; Electronic Subcontracting Reporting System, eSRS; the past performance databases, the Federal Awardee Performance and Integrity Information System, FAPIIS, Contractor Performance Assessment Reports System, CPARS, and Past Performance Information Retrieval System, PPIRS; and the Federal Funding Accountability and Transparency Act, FFATA. (ibid)

Can’t find what you are looking for on any site? Give us a call, we can help.

Not a “tricky” October 31st Deadline

A Multiple Award Schedule deadline is fast approaching. All contractors must do the following to remain in compliance with the MAS Consolidation Mass Mod A812:

  1. Update your catalog in GSA Advantage
  2. Update your Price List (text file) (GSA Interact September 8, 2020)

To remain in GSA Advantage, your SIP or EDI catalog to the consolidated MAS SINs must be updated before October 31, 2020, or you risk disruption to your catalog status or access to eTools. To accomplish the update, see the SIP/EDI Catalog Update Guide. All catalog submissions must be approved by your CO. (ibid)

Additionally, all schedule holders must update their Price List (Text File) using the MAS Consolidation Price List Guide, organizing their contract offerings under the new SIN structure. (ibid)

To aid contractors with their updates, webinars are being offered as well as a Vendor Support Center Help Desk at vendor.support@gsa.gov or call 877-495-4849. (ibid)

Having trouble getting your questions answered? Give us a call.

Yes Virginia, There Is a Data Ethics Framework

Earlier this month, GSA was given the opportunity to develop a Data Ethics Framework to assist agencies in making ethical decisions as they acquire, manage, and use data. A completed version of the report is expected by the end of 2020. (GSA Data ethics framework action 14 draft, September 2020)

The Framework incorporates four parts:

  • About the Data Ethics Framework — explains the purpose and audience of the Framework.
  • Data Ethics Defined
  • Data Ethics Tenets — provides seven principles for using data ethically within the federal government.
  • Data Ethics Tenets in Action — details data ethics benefits and demonstrates how the Tenets guide data activities within agencies as well as federally sponsored programs. (ibid)

The Framework originated to guide ethical decision making by federal employees who collect, manage, or use data to support their agency’s mission. It acts as guidance to encourage ethical decision making, but isn’t required. Its audience includes “anyone in the Federal Government who works with or leads work involving data, which includes all employees, contractors, researchers, and other partners who work on behalf of the government.”

According to the Framework, “Data leaders and professionals should adhere to all applicable legal authorities, as ethics are reflected and reinforced in existing laws.” Additionally, “agency leaders are encouraged to maintain up-to-date, comprehensive ethical standards regarding data use and staff are responsible for learning and applying agency guidance. In addition, if a person works in an area with recognized professional ethical codes of conduct, they should be aware of those standards and strive to uphold them.” (ibid)

Have a question about the Framework or the definition of data ethics? Give us a call we can explain.

Leftover BPAs

If you have a Blanket Purchase Agreement (BPA), you may have just been given a bit of a reprieve regarding the merge into the General Services Administrations’ (GSA) consolidated Multiple Award Schedule. (Federal Computer Week, August 31, 2020)

According to GSA Administrator Emily Murphy, GSA is allowing a few BPAs to work through their lifecycles as opposed to forcing them into the consolidated Multiple Award Schedule. Murphy feels it could take up to five years to move completely over to the consolidated schedule but counts on it being much sooner.

As of the end of July GSA moved to Phase 3 of the MAS consolidation. Nearly 100 percent of vendors have updated their contracts and terms and conditions for the new solicitation. Murphy said, “We’ve got 99 percent of them onboard,” and will “work with [the remaining ones] on the best way to transition.” (ibid)

Wondering about your long-standing BPA? Give us a call.