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Government Contractor’s Blog

Effectiveness of TDR is TBD

GSA Responds to Criticisms of TDR

The new pilot program for Transactional Data Reporting has met widespread criticism, leading many to question its supposed benefits.

GSA wrote the Transactional Data Reporting (TDR) requirement as an alternative to the Price Reduction Clause (PRC) and Commercial Services Practices (CSP) provision, in response to contractor complaints. The CSP provision requires government contractors to inform GSA of any discounts they offer to commercial partners. Meanwhile, the PRC requires contractors to offer government clients discounts equal to those given to commercial customers, as determined by the contract itself.

Because vendors tend to loathe these clauses, the TDR requirement generated widespread enthusiasm before its June launch. However, since then, it has met with criticism from the contractor side and has included anecdotal evidence of contracting officers still requesting CSP, or CSP-esque information from contractors enrolled in the TDR pilot.

Kevin Youell Page, the deputy commissioner of the Federal Acquisitions Service has publicly stated that “We haven’t really heard from anyone that this has specifically happened.” Most of the criticism appears based more on worries that COs could still require these, as well as general apprehension. Nonetheless, Youell Page is trying to answer feedback and reform the program. FAS has set up an email address exclusively for questions, comments, and concerns about the program; worked closely with the inspector general’s office to alleviate confusion; and continues a cross-country campaign to train and educate contractors and stakeholders.

This is a dramatic shift, made more  so by the risks associated with the new administration. GSA has only committed to a three-year pilot, and as yet the Trump administration has not moved to support TDR. This creates concerns about the liability of participating contractors for PRC and CSP data after the pilot ends.

Satellite of Love-ing IT Schedule 70’s new SIN

GSA launches new Special Item Number for Satellites

The next IT Schedule 70 refresh will include a new Special Item Number (SIN), 132-41, devoted exclusively to Earth Observation Solutions (EOS)!

The SIN will provide services related to “global coverage, imagery, archive storage and distribution, monitoring, base maps (mosaics) and earth observation solutions for accurate, mission-critical information.” This can serve a wide array of uses, like obtaining climate, defense, and weather data.

GSA published the Request for Information in February, launching work on the SIN. They expect to launch it for vendors in early June.  At that time, partners with satellite tech can add their services to the contract.

With the rapid acceleration of technology and expanding possibilities offered by satellites, this addition will bring inventive solutions to the GSA schedule. On the vendor side, the SIN will make it easier for innovative partners to pursue the addition of satellites.

GSA will host a webinar on May 18th, 10:00 am EST to discuss the development and resulting changes. To participate, register at https://meet.gsa.gov/eos05182017/event/event_info.html.

News You’d Rather Not Use…

Our sources throughout the GSA product schedules are indicating that the recent process for submitting a modification to the CO for approval before actually submitting it through eMod will be codified in the next round of Schedule refreshes.

While this will cut down on a CO’s official modification time in-house, it will probably mean longer wait times for contractors to obtain mod approval, as there will be no clock measuring the time that the CO will have the mod pre-submission.

We are hopeful that this analysis is incorrect, and your CO will understand that your Schedule modifications require timely approval and only assist the contractor in selling more products to the government. Hopeful….

Alert!

All GSA Schedule holders with Contracting Officers stationed in Texas should be aware that their COs will be in training next week, 24-28 April. They will most likely be unavailable to you for questions and modifications.

Ch Ch Ch Changes … to the GSA Schedules

GSA is preparing to release a round of Schedule refreshes next month, so prepare for a bunch of mass modifications. And if you are in the midst of completing your GSA Schedule proposal, either submit now or expect to review the entire solicitation again come April.

New policies represented in the GSA Schedules will include small business subcontracting changes, updates to those entities that can access the Schedules for purchases, SCA adjustments, and modifications in the Disaster Purchasing Program. For instance, the Red Cross and other qualified organizations will have access to the Schedules during emergency preparedness and disaster relief. Additionally, the following specifics may be of interest to our clients:

  • Subcontracting plans for ‘other-than-small’ businesses will now be at the CO’s discretion. For all intents and purposes, however, these will still have to be submitted with your proposal.
  • The Pathways to Success training has been removed as a requirement for streamlined offers.
  • Montenegro and New Zealand are now TAA compliant countries.
  • Federal contractors now receive paid sick leave.

If you have any questions about how these changes will affect your Schedule contract, feel free to give us a call at 301-913-5000. We look forward to assisting you with this new round of changes.