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Government Contractor’s Blog

OLM rule finalized

OLMs, Order-Level Materials, are goods and services that are not covered by original FSS contracts or BPAs, but are necessary to the completion of a particular order. Historically, FSS prohibited agencies from adding them into task orders and delivery orders placed against contracts. This meant agencies could only acquire them by placing task orders on multiple-award-contracts, and were hence forced to make two separate procurements. However, on January 24, FSS issued a final rule to authorize agencies to acquire OLMs when placing orders, offering greater flexibility and efficiency.

The rule makes clear that OLMs are not open-market items, but rather may be added to an order under the new GSAR provision 552.238-82. The list of schedules authorized to allow for OLMs should soon be available here. 

Under the new rule, agencies may add OLMs up to one-third the value of the order, with some restrictions. Except for travel OLMs, each proposed OLM above the simplified acquisition threshold of $150,000 should come with three quotes. This ensures that prices are fair and reasonable.

Industry partners with affected GSA FSS schedules will receive bilateral modifications from GSA adding the OLM Special Item Numbers (SINs) to their GSA contracts. Before accepting, contractors should ensure that they have policies and procedures in place to comply with the three-quote requirement and the OLM limitation of one-third of the total order value.

Overall, this looks like a welcome change that will increase efficiency and decrease administrative costs.

Hard Shutdown

Shutdown? Shut up!

Since Saturday, the United States government has been closed, shut down, unplugged (etc.), including the General Services Administration (GSA) and FAS. Right now, GSA is deferring to 4220.1K ADM, the Order which dictates “Operations in the Absence of Appropriations.”

What does this mean for our clients? Unfortunately, if you currently hold a GSA Schedule, you will not see any work done on your contract modifications and will not receive any government payments. Work for government agencies under the GSA Schedule must be halted during this time unless it is of mission critical importance (you will have been notified if this is you). Companies with proposals into GSA will be in a holding pattern for now, whether they are recently submitted and being triaged to the correct Contracting Officer, under administrative review, in negotiations, or awaiting final award.

“GSA’s role as an aggregator of large numbers of government assets and a supplier of critical tools, equipment, and supplies to other Federal agencies requires that GSA retain adequate staffing under a lapse in appropriations in order to protect Federal property under GSA’s custody and control and to continue to provide critical support to other Federal agencies’ exempt and excepted activities necessary for the protection of life and Federal property.”

In other words, GSA is mostly shut down. Buildings remain open for maintenance, power, and cleaning in a reduced capacity. Small crews are also being kept around to ensure protection of GSA assets and property, and to support other essential Federal agencies. GSA is held more responsible than other agencies to maintain their regular tasks. Think of it as a GSA skeleton crew. When the shutdown is over, GSA will update plans, decide what to do about missed events, and catch up with all the work piling up right now.

We are hopeful this shutdown ends soon. Stay vigilant, folks!

Heard it Through the GSA Grapevine…

A plausible source at GSA has told EZGSA proposal specialists that the minimum yearly sales requirement for GSA Schedules is going to be increasing soon.

While this won’t be a problem for contractors that already more than meet the current sales requirement of $25,000 in the first two years and $25,000 per year subsequently, it could make it even more difficult for those businesses that struggle with selling off their Schedule.

If you need help or have questions about this increase, please contact your EZGSA proposal specialist or call 301-913-5000.

Get your (webinar) Links in!

GSA Reopening the Office Supply Schedule with New (and improved?) SINs

GSA is opening Schedule 75 to new offers after a number of years, and they’ve added a new Special Item Number (SIN), called Office Supplies Fourth Generation (OS4).

SIN 75-200 for Office Products  have updated requirements, including a demonstrated ability to meet all environmental reporting and green product requirements, a system to comply with the Trade Agreements Act, and updated Letter of Supply requirements. Overhauled  Letters of Supply will also be required for 75-85 (Restroom Products) and SIN 75-210 (Office Services).

The optional requirements for all above SINs are AbilityOne-Certifications and Transactional Data Reporting. OS4 includes SIN 75-220 for Office Products and Services as well as SIN 75-280 for Overseas Office Products and Services. There is no deadline to submit an offer for these SINs.

Read more and leave comments here.

A web conference discussing these changes and answering questions will be held on January 9 at 1:30 Eastern Standard Time. Tune in here.

 

The Contract-Gift that keeps on giving

GSA offers continuous contracts to successful MAS contractors

With so many of our current clients approaching the sunset of their 20-year contract Schedule periods, we are pleased that GSA has finally released an official rule to help with ongoing Blank Purchase Agreements (BPAs).

In the past, the end of the Schedule options meant contractors had to perform a juggling act with their government clients to keep BPAs from becoming inactive or going to a competitor. When BPAs extend past the expiration date of their underlying MAS contracts, orders can be placed until the last day of the schedule contract, but no option periods can be used after the Schedule contract expires.

GSA has finally allowed contractors to maintain overlapping or continuous contracts. These contracts are essentially duplicate MAS contracts for different periods of performance. Holding two contracts is not mandatory, and for many contractors, would be unnecessary. But for others, it can be a business-saver.

For those that do need it, continuous contracts will allow contractors to complete work under BPAs, while simultaneously seeking new  business opportunities. Contractors should be aware that this may result in extra reporting burdens, but will be happy to know that MAS now has a streamlined process and revised requirements for previously successful contractors submitting offers for new contracts under the same schedule.

Readiness assessments, financial statements, corporate experience, open ratings report, and relevant project experience requirements have all been eliminated or greatly reduced for successful MAS contractors. To qualify, contractors must propose the same Special Item Numbers as those awarded under existing contracts, meet the minimum sales requirement under the existing contract, and demonstrate a pattern of satisfactory past performance.

For more information, check the vendor support center or contact us here at EZGSA (301-913-5000).