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Government Contractor’s Blog

Telework, the New (Temporary?) Norm

In a recent letter to her contracting staff, Soraya Correa, Homeland Security’s chief procurement officer, asked her contracting staff to stay apprised of the outbreak of COVID-19, before taking any trips. She is relying on the honor system for employees who must take trips to “affected areas, to contact their managers prior to their return to discuss possible telework or leave options.” Also, if they’ve been in close contact with a person “known to have COVID-19” or if airport screeners told them to self-quarantine after returning from overseas travel. Correa went on to say, “if contract performance is affected due to the COVID-19 situation, such as the need for alternate work locations, or travel or schedule changes, the contracting officer is the authority to discuss this with your company.” (FCW, March 9, 2020)

A spokesman for the Professional Services Council expects adjustments of this nature to be the new normal. He expects alternatives to how and where contracting personnel work, with programs necessitating a high level of security being prioritized. (ibid)

Federal agencies are already beginning to shake things up. One example is a recent notice on beta.SAM.gov, where the Department of Defense suggested that attendees of its National Cyber Range Complex Event Planning, Operations, and Support contracting meeting in Florida next week, have alternates at the ready. The notice also mentioned staying tuned in, as the outbreak could cancel the event. (ibid)

Need help determining if your contract may be at risk due to travel/work restrictions as a result of the virus outbreak ? Give us a call.

Lead Times! Get Your Lead Times Here!

When is the actual start and end of Procurement Administrative Lead Times (PALT)? The Office of Federal Procurement Policy (OFPP) is working on a measurement to answer this question, which seems to be not only a grey area in the procurement arena but a disputed one, as well.

OFPP is looking at the 2019 National Defense Authorization Act, section 878, which describes PALT as “the time between the date on which an initial solicitation for a contract or order is issued by a federal department or agency and the date of the award of the contract or order.”  OFPP would like to marginalize procurement process delays and believes having this definition in place will minimize those delays. (FCW, February 24, 2020)

The Professional Services Council and the Council of Defense and Space Industry Associations both welcome the definition being put in place. However, naysayers argue the OFPP language misses pre-solicitation work, such as: creating a requirements planning package that provides solicitation facts prior to issue; or when a particular contract is initially funded. According to some, the current definition ignores pre-solicitation lead time factors which do contribute to the time needed for a contracting officer to move from contract request to contract requirement in solicitation. (ibid)

Wondering how this affects your upcoming proposal efforts? Give us a call.

beta.sam.gov Hiccup Hiccup

When FedBizOpps (FBO) migrated to beta.sam.gov, everyone expected a few hiccups. Now three months in, it’s fair to say government contractors have been experiencing more than just a few hiccups. GSA says the number of help desk calls they get is no more than they got with FBO. However, the frustration over beta.sam.gov runs deep.

Last week contractor discouragement came to a head when the Professional Services Council sent GSA a letter airing not only their complaints but also their concerns. The 22-page letter outlined the four areas of greatest concern:

  • Access Challenges;
  • Search Parameters;
  • Capability to receive contract information;
  • Difficulties in how the site displays information. (Federal News Network, February 17, 2020)

At EZGSA, we have found problems with data organization, standardization, and even saving information. GSA seems ready to add new capabilities next month, but should they? Many feel the backend structure should be fixed before the next phase, moving the Federal Procurement Data System-Next Generation (FPDS-NG) reporting capabilities to beta.sam.gov in March. (ibid)

Large companies are better able to handle the costs associated with down time or lost data. Small businesses that must  spend thousands of dollars on software, just to get what they got before the FBO migration, are at a great disadvantage.

Need help navigating beta.sam.gov? We will do our best to help and take away some of the frustration. Give us a call.

New Cybersecurity Certification Requirements

The Office for the Under Secretary of Defense and Sustainment (OUSD (A&S)) recently released its Cyber Security Maturity model Certification (CMMC). DoD stakeholders, University Affiliated Research Centers (UARCs), Federally Funded Research and Development Centers (FFRDCs) and the Defense Industrial Base (DIB) all had a hand in developing the CMMC model. This model measures cybersecurity maturity using five levels (from basic to advanced) and aligns a set of processes and practices with the type and sensitivity of the information to be protected and any associated threats to that information. (CMMC Model v1.0, January 30, 2020)

DoD’s CMMC enhances the protection of:

  • Federal Contract Information (FCI) provided or generated by the government, but not intended for public release
  • Controlled Unclassified Information (CUI), which requires safeguarding or dissemination consistent with laws, regulations and government-wide policies. (ibid)

The CMMC model includes the safeguarding requirements for FCI spelled out in FAR clause 52.204-21 and the security requirements for CUI stated in the National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171 per DFARS clause 252.204-7012 [3,4,5].

Included in the CMMC model is a certification piece verifying the implementation of cybersecurity maturity measure processes and practices. This is intended to deliver assurance to the DoD that contractors and subcontractors can sufficiently protect CUI at a level equal to the risk. (ibid)

To obtain a full overview of the CMMC Model, domains, practices, and processes, please review the Cybersecurity Maturity Model Certification.

Have questions about the effect on your current contract or one in works? Give us a call.

Phase 2: Resistance is Futile

Although we covered this last month, it’s worth another review  as GSA moves to phase two of the MAS consolidation.

As you know, GSA is merging the Multiple Award Schedule (MAS) program contracts from 24 different schedules into one. Notices of changes to terms and conditions for current contract holders under the MAS program should be received by contract holders in the coming months.

The consolidated schedule makes it simpler for the government to make purchases and will roll out in three parts:

  1. Creation of a new contract vehicle for all future acquisitions
  2. Bring current contract holders onto the new consolidated schedule
  3. Consolidate those businesses that have multiple contracts across many schedules(Federal Times January 31, 2020)

Terms and conditions are being standardized and all current contract holders and contractors, placed on the consolidated schedule, must respond to them by July 31, 2020. (ibid)

Questions about the consolidation and how you and your contracts are affected? Give us a call.