GSA is about to make Cloud purchases a whole lot easier

GSA is about to reveal a plan for a governmentwide marketplace for cloud solutions. This new marketplace will not only make it convenient, it will also set up a one-stop-shop for agencies to purchase commercial Software as a Service, Infrastructure as a Service, and Platform as a Service, offerings. (FedTech October 7, 2021)

On a recent webinar, Laura Stanton, assistant commissioner for the Office of Information Technology Category in the GSA’s Federal Acquisition Service, said, “We’re looking at how we put together a cloud marketplace that then becomes a buying platform for agencies. We want to put together not just a framework, but a market contractual vehicle that will allow our agencies to buy these core cloud services that we’re seeing them need more and more.” (ibid)

The GSA marketplace will provide agencies with professional IT services as well as post-award contract management tools. It would also set the requirements to verify cloud services meet the baseline security and adherence to guidance from the Federal Risk and Authorization Management Program (FedRAMP). (ibid)

GSA wants to streamline the entire cloud procurement process for agencies. According to Laura Stanton, “GSA uses the cloud and cloud-related IT professional services special item number (SIN) 518210C as a vehicle for multiple-award procurements. The contract type can be used to acquire cloud computing services, as defined by the National Institute of Standards and Technology.” Stanton said that GSA is “hearing that agencies have to go to multiple places to buy cloud. We decided it was time to take the next step.” (ibid)

An RFI is expected early in the new fiscal year, which began October 1, 2021. (ibid)

Questions concerning the upcoming RFI? Give us a call.

Not everyone is sold on the Transactional Data Reporting (TDR) pilot

Almost five years ago GSA launched the Transactional Data Reporting (TDR) pilot to replace the Price Reduction Clause (PRC). GSA’s goal is to use the data received, to obtain better pricing from contractors. GSA calls TDR a success, critics are not so quick to agree. (Federal News Network May 10, 2021)

Jeff Koses, GSA’s senior procurement executive said, “GSA has successfully demonstrated the value of TDR under the existing scope of the pilot. It has shown steady progress over the past four years, met most of the pilot’s objectives in the most recent year, and has made the necessary investments to leverage TDR’s potential in the years to come. We will continue to make improvements, especially in contracting officer usage.” However, Koses made no mention of using the TDR information in 2019 or 2020 (ibid).

Some argue that TDR works on paper, but not in reality. Many contracting officers are reluctant to use the data for decision-making. One industry expert went so far as to say, “I have not experienced any negotiations based on TDR data in order to form an opinion.” Others have suggested that the data is incomplete and that GSA has no strategy to back the pilot. (ibid)

One consultant pointed out that as more companies participate in TDR, the IG’s ability to audit prices before an award is made is more difficult. She noted, “under the TDR pilot, the population of auditable contracts has ostensibly been cut in half. When you remove the major resellers and the integrators, what remains are largely professional service contractors and products companies under Schedules 84 (Law Enforcement), 71 (Furniture), and 66 (Scientific). The audit threshold for annual sales is also reduced due to the smaller pool of contracts from which the OIG is selecting. Small businesses who would never have been a blip on the OIG’s radar are now at much higher risk of pre-award audit.” (ibid)

Another complication is GSA’s move toward unpriced contracts under Section 876 of the 2018 National Defense Authorization Act. The Act makes the Price Reduction Clause as well as TDR less necessary because the burden is on vendors to provide the lowest price possible as part of contract negotiations. (ibid)

Koses said GSA will refine and consider:

  • The ability of Federal Supply Schedule contracting officers to use transactional data for price negotiations in lieu of commercial sales practices and price reduction clause disclosures
  • The impact of an expanded data collection on GSA’s ability to use the data it currently collects
  • The impact on current/future GSA schedule contract holders
  • Communication to industry partners
  • Training and tools for category managers not impacted by TDR
  • Possible impacts on other FAS initiatives such as the National Defense Authorization Act (ibid)

So when will the pilot move to production? The waters remain murky. Whether the IG will move from the production stage should be made more clear when the Inspector General report on the TDR pilot is released, in the coming weeks. Vendors should be ready to invest in systems to collect and report pricing data, should the TDR pilot go into production.

Questions concerning how to collect and report pricing data? Give us a call.

COVID-19 actually helped small businesses do business

Due to the pandemic, the federal government has expanded remote network access to assist a dispersed workforce. This in turn has motivated reforms to the procurement system.

According to Roya Konzman, acting division director for solutions development at General Services Administration’s Federal Acquisition Service (FAS), “suddenly there was a need for new hardware, software and network access security, so we advised our Small Business Administration, Department of Veteran Affairs and Social Security Administration on their procurement strategies. GSA empowered its contracting officers to expand its rated orders authority. These orders are issued in accordance with the defense priorities and allocation system, and rated orders applied to IT capabilities included teleworking and health care solutions such as VPN accounts, virtual desktop infrastructure solutions, laptops, and mobile devices, and also covered personal protective equipment such as medical products hand sanitizers and disposable gloves.” (GovernmentCIO Media & Research April 6, 2021)

A national emergency allows the use of rated order authority. It authorizes GSA to prioritize a solicitation on behalf of an agency to buy goods and services. If a contractor receives a rated order, the contractor must prioritize that order ahead of other orders in the queue. (ibid)

There were so many rated orders issued to large contractors that individual suppliers often had a hard time meeting demands within the allotted timeframe. The result was federal agencies looked to enlarge their contracting base to include specialized smaller and mid-sized contractors. (ibid)

Because smaller firms do not have the “red tape’ that larger firms have, they can often change directions quickly. This makes smaller firms extremely valuable during times of national crisis. (ibid)

The federal government invested in video conferencing software and remote connectivity during the pandemic. This affords vendors the opportunity to demonstrate their products to various procurement offices. Additionally, agencies can quickly evaluate a large range of potential contractors. Which helps potential contractors who might have otherwise been overshadowed by larger vendors with preexisting relationships. (ibid)

Do you have a specialized product that the federal government needs? Give us a call.

 

FY 2021 SubK Reporting Deadline Extended

The Small Business Administration (SBA) is extending the period for subcontract reporting for fiscal year 2021. The extension allows Federal Contractors (FCs) extra time to correct any issues experienced during the pandemic as well as Federal Agencies (FAs) extra time to review the reports. This will be the final Subcontract Reporting extension. The timeframe for FCs to revise rejected reports is not extended and remains unchanged. (Small Business Administration Notification March 5, 2021)

Extensions provided by the SBA include:

  • 15 days for FC’s report submission due dates and for  the FA’s review periods for the FY 2021 ISRs and SSRs
  • 45 days after the end of the reporting period for FCs to submit their ISR and SSR and 45 days after contract completion if applicable
  • 75 days from the reports’ ending dates for FAs to acknowledge receipt or reject the initial reports
  • 30 days after receipt of a rejection notice, per FAR § 52.219-9(l), for FCs to revise rejected reports
  • 30 days after submittal for FAs to review revised reports

The subcontract report extensions are effective immediately. This pdf contains the formal notice SBA provided for the extension notification. (ibid)

Have questions concerning your ISR or SSR or a rejected report notice? Give us a call.

GSA Industry Webinar

GSA Federal Acquisition Services (FAS) is hosting an industry webinar on 24 March via Google Meet and focusing on contract holders of two Multiple Award Schedule (MAS) categories, MAS Travel and MAS Transportation and Logistics Services. These categories were formerly on Schedules 48 and 599, respectively. (GSA Interact, February 19, 2021)

The webinar will highlight the following:

  • GSA Advantage! price lists guidance
  • Required documentation when exercising an option period
  • Responses to vendor questions submitted in advance (ibid)

The deadline for questions and comments is 3:00 PM (ET) Monday, March 1, 2021. Questions must be submitted by email to onthego@gsa.vog with the subject line “MAS TTL March 2021 Quarterly Webinar Question” along with your contract number. Copies should go to lily.thompson@gsa.gov and jeanette.quitoriano@gsa.gov. (ibid)

The meeting will begin promptly at 2:00 PM (ET) with the following meeting id: https://meet.google.com/gwu-jgtq-ism.

Questions concerning MAS changes and updates and how they might affect your current contract or upcoming bid? Give us a call.