CPARS is getting a refresh

For over a decade, the Office of Federal Procurement Policy (OFPP) has encouraged government agencies to increase their research and evaluation of contractor performance on contracts, with little effect. (Federal News Network April 12, 2021)

The general consensus is that the current Contractor Performance Assessment Reporting Systems (CPARS) is broken. Contractors and Contracting Officers feel it inaccurately rates performances while also being burdensome. For the past two years, Mike Smith, a former DHS director of strategic sourcing and now an executive vice president at GovConRx, has led an effort to rebuild CPARS. His goal, “make sure it results in good information and the information is more strategic and tactically used.” (ibid)

What are some of the problems with CPARS? Many contracting officers rate contractor performances as satisfactory because it takes too much of their time to verify exceptional or outstanding performance and too much time trying to explain why a rating might be below average or poor. (ibid)

DHS is looking to solve this problem through a pilot application of artificial intelligence (AI). DHS recently awarded contracts to five companies to demonstrate their ability to build production-ready software. User groups will view demos using software-as-a-service (SaaS). The user groups are, The departments of Commerce, Energy, Interior, Veterans Affairs, and Health and Human Services as well as GSA, NASA, the Air Force, and the U.S. Agency for International Development. The agencies gave the 5 companies in the pilot, 50,000 anonymous procurement records, to assist in training the AI. The goal is to decide which technologies will move to phase 3 in June with an actual launch in January 2022. (ibid)

GSA has some barriers to overcome too. Contracting officers must see the value in vendors providing self-assessments on certain projects. GSA senior procurement executive Jeff Koses sent a memo in February recommending the use of vendor self-assessments s one step in the overall CPARS process. The memo is a permission slip, of sorts, for contracting officers to begin asking for self-assessments as one part of the CPARS process. This should alleviate some of the burden on contracting officers.(ibid)

Mike Smith, a former DHS director of strategic sourcing and current executive vice president at GovConRX said, “you wouldn’t believe how many contracting officers refuse to take input from industry because they think they aren’t allowed to. As a contracting officer, I’d rather have a back and forth at least by midyear, if not before, so we can adjust course and have a common understanding at the end of the performance period and there are no surprises about ratings and the basis of that rating.” Most agree that good contractors will jump at the opportunity to do a self-assessment because they will finally be able to have input into the process. (ibid)

CPARS should also help small businesses. When contracting officers see the small business has done larger jobs and done them well, through a relevancy search and high CPARS, they are a lot more likely to award them a contract. This in turn helps the contracting officer make better-informed decisions through the use of data. (ibid)

Questions concerning self-assessments and the intricacies involved? Give us a call.

 

 

EZ-ier requirements for COVID efforts at GSA says EZGSA

GSA’s Multiple Award Schedule (MAS) program may be used by state and local governments to procure commercial products, services, and solutions necessary to respond to the pandemic. GSA is providing additional support by issuing Acquisition Letter (AL) MV-21-03 and Supplement to further aid America in response to COVID-19. (GSA Interact April 14, 2021)

AL achieves this by:

  • Temporarily waiving (3) MAS solicitation requirements in MAS provision SCP-FSS-001 when a company is proposing products/services to support COVID-19 efforts.
  • The AL waives:
  1. The requirement to possess two years of Corporate Experience
  2. The requirement to submit a Relevant Project Experience for each SIN proposed
  3. The requirement to submit an Annual Financial Statement for the previous two years (ibid)

The AL, however, does not change the following:

  • Certain vendor instructions regarding the submission of a Corporate Experience narrative, Letter of Commitment/Supply, Past Performance Information, Quality Control Plans
  • Category/SIN specific technical requirements outlined in the MAS Solicitation category attachments
  • A Contracting Officer’s overarching responsibilities especially determining fair/reasonable pricing, ensuring compliance with vendor instructions, and making a responsibility determination in accordance with FAR subpart 9.1 (ibid)

AL applies to all MAS large categories, subcategories, and SINs under the following conditions:

  • New vendors proposing products, services, and/or solutions in direct support of COVID-19 efforts
  • Current MAS contractors adding service SINs in direct support of COVID-19 efforts (ibid)

AL does not apply under the following conditions:

  • Any offers or modifications which include products, services/solutions that do not directly support COVID-19 efforts
  • To VA MAS for medical equipment, pharmaceutical services, or supplies (ibid)

GSA is doing a number of things to support the ongoing COVID-19 efforts. The following are to name a few:

  • Deferring MAS contract cancellations when minimum sales haven’t been met under I-FSS-639 Contract Sales Criteria
  • Issuing a non-availability determination for Trade Agreement, Buy American Statute Class Determination, allowing contracting officers to temporarily award non-TAA compliant product to support COVID-19 requirements
  • Purchase Exceptions from the AbilityOne Program
  • Implementation of Emergency Acquisition Flexibilities (ibid)

GSA/FAS has many mechanisms for its Federal Partners to access the vital supplies and services required to meet the COVID-19 pandemic. For companies who would like to reach the government market beyond the MAS program, the Commercial Platforms program provides options to partner with several commercial e-marketplace platforms. It is also possible to partner with an existing MAS contractor as a subcontractor, providing part of a total solution to an agency’s COVID requirements. (ibid)

Questions concerning AL, what it does, doesn’t do, or do you now qualify for GSA? Give us a call.

 

 

 

 

Bots Can be Your Friend

It’s been just about a year since Dr. Michael Wooten, the Policy Administrator for the Office of Federal Procurement, disclosed his plan to remove friction from the acquisition process. His intention is to rely on robotics process automation (RPA) as well as a few additional concepts to lessen the burden on contracting officers. (Federal News Network, October 12, 2020)

One way Wooten plans to do this is through the reduction of procurement administration lead time. Wooten recently spoke at the ACT-IAC Acquisition Excellence conference and said, “We look to accelerate the use of facilitated requirements development workshops, known as SAWS. We should enhance the requirements development process with the same technologies used to finish my sentences when I send texts or emails. This is no pie-in-the-sky vision. The technology exists today. In fact, the Department of Interior is piloting this approach. Under one of its contracts, a contractor supporting the Department of Interior applies natural language processing and machine learning tools to coach Interior’s acquisition community through the acquisition process. These artificial intelligence tools collect data to identify training needs. These data support management decisions to support better performance through training or process improvements.” (ibid)

When purchasing anything from help desk services to a fighter jet, AI and natural language processing tools pull clauses and requirements, which are applicable, by scanning previous contracts. The next step hopefully finds the manager performing minor tweaks to the language because most of the language has been used previously. GSA has been using these facilitated requirement development workshops (SAWS) since 2015 for BPAs and DoD has used SAWS since 2012 for service acquisitions over $1 billion. (ibid)

The acquisition community is taking a hard look at automation. RPA has been applied to the procurement process by the IRS, the Army, and GSA. Wooten feels RPA will improve compliance and ultimately become routine. He said, “these process automation tools can take on the ‘flow-chartable’ tasks. These tools will execute program decisions. In this fashion, automation can enable a compliance system that enables greater speed and accuracy. As process automation tools take on program decisions, they free people to make non-program decisions. They free people to exercise critical thinking and professional judgment. They empower people to create solutions.”

IRS has two programs under the Pilot IRS initiative:

  • Contract Clause Review:  a tool allowing a procurement document to be uploaded while answering questions about the document. Within seconds a compliance report is generated. Missing characters, text, and incompleteness is checked while at the same time syncing to the FAR, the Treasury Acquisition regulations, and the IRS acquisition policies. The tool is expected to have a large Return on Investment.
  • Contractor responsibility determination will automatically, prior to contract award, verify a company is eligible to do business with the government. Instead of a manual process, a bot will search databases, sending a report back to the employee within five minutes.

The Army launched another form of automation, a bot to retrieve information from SAM.gov and FAPIS.gov and summarize the information in a formatted template. Air Force and Navy should be utilizing the bot in fiscal 2021. Liz Chirico, the acquisition innovation lead in the Office of the Deputy Assistant Secretary of the Army for procurement said, “our team is looking into a couple of other interesting intelligent automation ideas. We are looking at automating some of the manual lookup processes for pricing so going to some of the public-facing pricing sites like GSA’s CALC and the Bureau of Labor and Statistics are two examples. We are also looking into streamlining the acquisition requirements process. That process often takes a lot of time and requires duplicative information, so if there is any way for us to streamline that and have all of the requirements stated upfront and have those templates and forms prepopulated.” Bots will probably also be used to ensure compliance with Section 889, prohibition of Chinese made telecommunications products. (ibid)

The IRS and the Army are using automation tools to move quickly through the procurement process and it’s likely the rest of the federal agencies are not far behind.

Questions concerning an upcoming bid and your company approvals through RPA or other automation processes? Give us a call.

Easier EULA Review Ahead?

GSA wants to shorten review time for end-user license agreements (EULAs) through an artificial intelligence and machine learning challenge. The challenge comes with a $2,500 cash prize and will be given to three teams who develop the top AI or ML solution to review EULAs terms and conditions. One of the selected teams will receive an additional cash prize of $12,500. (Fedscoop, July 6, 2020)

On average, a GSA contracting officer takes one or two weeks to review EULAs, but we have experienced wait times of much longer — even up to six months — when GSA legal gets involved. EULAs give specifics on the legal use of software and services; GSA ensures that the terms and conditions are compliant with government rules and regulations.

The current process is manual and mandatory prior to contract award or modification. However, with the right AI or ML solution, the document review can be automated and flagged for questionable language. (ibid)

GSA provided the following: training data, reference documents, and a sample validation file. All solutions submitted must accept the EULA documents in Microsoft Word and PDF formats. (ibid)

Solutions will be scored on a scale of 1-5 in the following areas:

  • technical evaluation
  • functionality and user interface
  • creativity and innovation
  • quality of demonstration

All solutions are the sole financial responsibility of the entrant, who retain ownership of the solution. GSA receives an irrevocable, paid, and royalty-free license to use and reproduce the three winners’ solutions.

Solutions must be submitted by August 20, 2020.

Questions about the challenge and the submission of your solution? Give us a call.

GSA, Pandemic Style

GSA is moving quickly to enact several initiatives while responding to the COVID-19 pandemic. Because the current state of emergency necessitates the Federal Acquisition Service to purchase medical supplies and other equipment at a fast clip, Contracting Officers have no choice but to react with a fair amount of speed and flexibility. (Federal News Network, May 1, 2020)

This includes:

  • changing policies for prompt payment and onboarding/offboarding of contractors
  • construction of the new e-commerce marketplace platform, which was paused during the first few weeks of the pandemic, is now moving forward, albeit at a much slower pace
  • monitoring other initiatives possibly impacting by the pandemic, such as Enterprise Infrastructure Solutions (EIS)
  • continuing corrective actions on Alliant 2 revised proposals
  • expanding the small business innovation research (SBIR) program, part three

Some government markets, like travel, have declined; however cleaning products and enhanced screening services have increased exponentially. (ibid)

Any questions about getting your product or service in front of government buyers? Give us a call.