DUNS Is Leaving

DUNS Is Leaving

GSA announced earlier this year they would be moving away from the proprietary Dun & Bradstreet’s Data Universal Numbering System (DUNS) in favor of an internally developed and managed Unique Entity Identifier (UEI).

GSA has been extracting itself from commercial proprietary handcuffs over the years, beginning with the Open Ratings requirement, which is now only necessary when a company lacks sufficient CPARS. These moves provide GSA with greater control across all agencies and will allow vendors to compete to provide the entity validation services, rather than provide a direct award to D&B. GSA’s plan is to phase the release of the UEI through December 2020.

Beginning December 2020, Federal contractors will obtain UEI through beta.sam.gov (or sam.gov by that time) registrations and annual maintenance. The new UEI will be twelve characters long and assigned based to separate legal entities or separate physical addresses. All contractors currently registered in SAM will automatically be assigned an UEI by December 2020.

You can learn more at GSA: https://www.gsa.gov/about-us/organization/federal-acquisition-service/office-of-systems-management/integrated-award-environment-iae/iae-information-kit/unique-entity-identifier-update

Coley GCS will be following up on this issue. Follow our blog for future updates.

D&B No Longer Accepting Orders for Open Ratings Past Performance Reports – Now What?

D&B No Longer Accepting Orders for Open Ratings Past Performance Reports – Now What?

When submitting a GSA Schedule Offer, GSA requires that you provide evidence of successful past performance. Typically, this requirement has been satisfied by ordering an Open Ratings Past Performance Report through D&B. However, as of Dec 6, 2019, D&B is no longer accepting orders for their Open Ratings Past Performance Evaluation Report. 

According to the latest Multiple Award Schedule (MAS) Solicitation, GSA permits three options for satisfying past performance requirements: 

Option 1: CPARS (preferred) 

Option one is to verify in eOffer that you have three (3) or more Contractor Performance Assessment Reporting System (“CPARS”) reports that:  

  1. were completed within the last three years,  
  2. represent at least three distinct orders/contracts, and  
  3. outline work similar to the scope of products/services included in the solicitation and for which you are proposing to offer 

Option 2: Open Ratings (NO LONGER AVAILABLE)

This option is not available at this time according to D&B’s website. We will update this blog when the government determines an alternative to the Open Rating report. In the meantime, use Options 1 or 3 to satisfy GSA Schedule Offer past performance requirements. 

Option 3: Past Performance Narrative 

Option three is developing a past performance narrative, which includes a list of relevant customer references. The narrative needs to explain why you cannot use method one or method two, and include up to five (5) references from customers for whom you have performed work within the past three (3) years that is similar in scope to products/services outlined in the solicitation.  

Changes in eBuy During the GSA Consolidation Initiative.

Changes in eBuy During the GSA Consolidation Initiative.

Everything You Thought You Knew About GSA Schedules is Changing.

GSA is rolling 24 GSA Schedules into one Multiple Award Schedule (MAS) that will include 12 large categories, 83 subcategories, and 316 Special Item Numbers SINS. To add to the complexity of this transition, GSA will require Transactional Data Reporting on some SINs, but not on others; and some SINs will include “Special Fees”. With all these changes happening, it can be very challenging to keep up.

The good news is that GSA has thought through the challenges that their consolidation initiative may create and have addressed many of them on its site and in GSA Interact. Ultimately, we believe this transition will benefit both buyers and for vendors; but like most change, it will be painful as we go through the transition.

One question that GSA had not addressed was how they will post opportunities on GSA eBuy where some contracts have transitioned to the new SINs while others are still under the old SINs. Traditionally, the Government buyer (CO/KO) who posts an opportunity to eBuy must select the appropriate SIN. Our concern was whether the Buyer would need to select both the old and new SIN, or would eBuy automatically select both so that vendors would not miss out on opportunities.

We reached out to Stephanie Shutt, Director of the Multiple Award Schedule Program Management Office heading the transition. She reassured us that GSA has developed a mapping system within eBuy that links existing SINs to the new SINs, so all vendors that qualify, whether under the new SIN structure or old SIN structure will receive notice of the opportunities.

That’s great news and reassured us that legacy contractors won’t miss out on posted RFQ’s during the transition. The MAS PMO office is setting a goal to have all legacy contracts transitioned over to the
consolidated MAS no later than July 2020.

All legacy contract holders should receive a mass modification in January 2020 to migrate their contracts to the new consolidated GSA Schedule. Vendors then have six months to work with GSA Procurement Contracting Officers to migrate their contract to the new MAS. There are many things one needs to consider when transitioning, especially where multiple GSA contracts are involved, such as open task orders, contract length, contract terms, discounting policies, etc. 

Coley GCS is already up-to-speed on these challenges and have identified ways to simplify the changes for our clients early in the calendar year. Call us for assistance on the GSA Consolidation initiative—we are ready to help!

You can reach us by email at [email protected] or by phone 210-402-6766.

GSA Schedule Holders Provide Needed Support During Disaster Recovery

GSA Schedule Holders Provide Needed Support During Disaster Recovery

As Florida begins to prepare for the swiftly approaching hurricane Dorian, disaster preparation and recovery by local and state government has become an increasingly relevant topic. The result of natural disasters can be devastating, and government officials are having the foresight to prepare for anticipated and unanticipated damages. If you have a GSA Schedule contract you may be wondering how to provide products or services to local and state government agencies that are in need during a natural, or man-made disaster such as hurricane Dorian.

How the Disaster Purchasing Program Works

The Department of Homeland Security allows all services and products available under GSA Schedules through the Disaster Purchasing Program, which in the event of a natural or man-made disaster, such as acts of terrorism or nuclear, biological, chemical, or radiological attack, equipment and services can be purchased by state and local governments from the GSA Schedules. This includes in preparation, response, or in recovery of declared disasters that is listed by Federal Emergency Management Agency (FEMA).The Virgin Islands and Puerto Rico have already been listed under Disaster Declarations on FEMA in the past few days due to do hurricane Dorian, and Florida is anticipated to follow suit.

State or local government institutions are defined in section 40 U.S.C § 502 (c) as “The term, ‘State or local government’ includes any State, local, regional, or tribal government, or any instrumentality thereof (including any local educational agency or institution of higher education).” This does not include contractors or grantees that may be eligible; eligibility requests can be submitted to GSA.

Authorized GSA Schedule contractors, contracts, products and services are identified with a Disaster Purchasing icon. This icon means that state and local agencies can purchase from these contractors or grantees only in event of disaster or recovery. These purchases are limited to GSA Schedule contracts and Blanket Purchase Agreements (BPAs) only. Schedule contractors identified with the Disaster Purchasing icon have the option of accepting orders placed by state and local agencies, and they are authorized to decline an order within a five-day period. Products or services purchased under the Disaster Purchasing Program must only be used for disaster preparation, response, or recovery from declared disasters.

Do Your Provide Products and Services That Support Disaster Relief Efforts?

GSA Schedule holders that provide these services need to make sure the government knows you can offer them under the Disaster purchasing program.  If you do not have this icon, you will need to submit a modification to update your contract. If you need assistance or have additional questions, reach out to Coley GCS at [email protected] or directly at 210-402-6766 and we will ensure that the contract is primed for these conditions.

Small Business Gets A Competitive Bump

Small Business Gets A Competitive Bump

SBA Proposed Rule to Size Standards extends calculations from average of three year of receipts to five years.

The U.S. Small Business Administration (SBA) posted a proposed rule to modify its method for calculating annual average receipts used to determine size standards for small businesses. SBA has proposed to change its regulations on the calculation of annual average receipts from a three-year averaging period to a five-year averaging period. The rule will not affect employee count under manufacturing NAICS.

The intention is to create size-standard consistency throughout the federal government and benefit small business in a strong economy. A five-year average will generally be lower than a three-year average, allowing:

  1. Mid-sized businesses who have just exceeded size standards to regain their small business status, and
  2. Advanced small businesses close to exceeding the size standard to retain their small business status for a longer period. It

The opposite would tend to be true in an economic downturn.

SBA Seeking Public Comments

SBA is allowing for public comments and feedback until August 23, 2019. The National Veterans Small Business Council and Coley GCS are in favor of this rule and have provided some sample language for those in favor of the extension:

“COMMENT REF: RIN 3245–AH16 – IN FAVOR.  This proposed rule change on the calculation of annual average revenues from a three-year averaging period to a five-year averaging period will be very helpful to small businesses of every size, especially those that have successfully grown to revenues above the three-year average for their respective NAICS code.  This rule change supports the small business, providing them additional time to prepare to successfully compete in the full & open marketplace, and also benefits Government by ensuring continued access to these successful small businesses. I am a small business owner (or employee) and support this rule change by SBA. “

SBA has also discussed changing HUBZone and WOSB certification requirements.

If you have questions of concerns about the SBA proposed rule, contact Coley GCS by phone at 210-402-6766 or by email at [email protected]

New Consolidated  Multiple Award Schedule Coming Soon & GSA wants Your Feedback

New Consolidated Multiple Award Schedule Coming Soon & GSA wants Your Feedback

MAS Consolidation is happening as previously advised. Plans to consolidate all 24 GSA Federal Supply Schedules into one mega schedule beginning October 1, 2019. GSA has released an industry Request for Information on changes and formatting to the new solicitation scheduled to arrive in the next fiscal year: (more…)

What is Best Value Source Selection

What is Best Value Source Selection

FAR 15.1 covers Source Selection Process and Techniques. FAR 15.101 covers the Best Value Continuum which provide guidance on when agencies should consider the Tradeoff process (Best Value) or Lowest Priced Technically Acceptable (LPTA) Source Selection.

Best Value should always be used when the deliverable requirements are not clearly defined, and there may be a risk of contractor performance. The tradeoff process allows tradeoffs between price and non-price factors, the tradeoff should justify the tradeoff in price.

The selection committee or contracting officer will determine if tradeoff process is appropriate and when that decision is made, the following apply:

  • All evaluation factors and significant subfactors that will affect contract award and their relative importance shall be clearly stated in the solicitation; and
  • The solicitation shall state whether all evaluation factors other than cost or price, when combined, are significantly more important than, approximately equal to, or significantly less important than cost or price.

When the tradeoff process is used, pay specific attention to the evaluation factors and how those items are evaluated. If you are unsuccessful in your bid, when appropriate, request a full debriefing.

Recently, John S. McCain National Defense Authorization Act for Fiscal Year 2019 made sweeping federal changes that limit the use of LPTA, especially on complex professional and IT solutions. These restrictions should increase the number of best value opportunities available, See our blog here.

What is Lowest-Priced Technically Acceptable Source Selection

What is Lowest-Priced Technically Acceptable Source Selection

The scourge of many professional service providers is the lowest priced technically acceptable (LPTA) source selection process. FAR 15.101-2 address LPTA source selection.

Product vendors, especially those acted as resellers of widely available products, should understand that nearly all of their federal opportunities will be price sensitive and value will likely not be considered. (more…)

Can You Decline GSA Schedule Orders?

Can You Decline GSA Schedule Orders?

A new email pops into your Inbox. It’s an order off through your GSA schedule directly through GSAAdvantage. Your first thought is elation – the schedule program is working!

(more…)
Why GSA Wants to Increase of the Micro-Purchase Threshold

Why GSA Wants to Increase of the Micro-Purchase Threshold

General Service Administration (GSA) and Office of Management & Budget (OMB) submitted the phase II report of their e-Commerce portal to Congress. (more…)

2019 NDAA Restricts Government Use of LPTA

2019 NDAA Restricts Government Use of LPTA

Federal professional services firms should all breath a sign of relief— one of the many changes of the FY2019 National Defense Authorization Act (NDAA) is the government-wide restriction on the application of Lowest-Priced Technically Acceptable (LPTA) as the basis of award on complex professional and IT services contracts. (more…)

GSA Schedule Consolidation Update

GSA Schedule Consolidation Update

Last December, GSA has stated a new initiative to create one mega-schedule consolidating and housing all existing schedules. This will be a massive undertaking that, we believe, will streamline scope expansion for new and existing schedule holders. 

Today GSA has shared some key information on the consolidation process.

GSA intends to release new terms and conditions in early June  that will reveal  more of the phase-out for public comments. Until then, we have heard that GSA will continue to award contracts and modifications under current terms and conditions until October 1, 2019, at which time the new terms and conditions are slated to take effect.

Current schedule holders will receive a mass modification to accept the new terms and conditions in January 2020.

Coley will continue to monitor and connect with GSA to get updates as things progress. If you have question or concerns, contact Coley.

Second Generation IT BPA out on eBuy

Second Generation IT BPA out on eBuy

Information Technology Government Opportunity Released!

The United States Air Force released a Request for Quote on March 04t, 2019 titled Second Generation Information Technology (2GIT) Blanket Purchase Agreement. The USAF has determined to make the 2GIT BPA a mandatory use vehicle for the replacement of the NETCENTS-2 (NC2) Products IDIQ contract.

The NC2 IDIQ was USAF’s go-to procurement option with a ceiling spend value of $6.9B. NC2 IDIQ expires in November 2019, making the new 2GIT GSA BPA a necessary vehicle for all software and product resellers on the GSA schedule.

The USAF must receive all responses to the 2GIT RFP by April 19th and all responses must be provided through the eBuy portal.

The stated intent of the BPA is to reduce redundancies and create fast and effective ways to order IT hardware and software commodities. 2GIT has five classes of products:

  • BPA Line Item One – Data Center (Compute/Store)
  • BPA Line Item Two – End User
  • BPA Line Item Three – Network (Connect)
  • BPA Line Item Four – Radio Equipment
  • BPA Line Item Five – Order Level Material (OLM)

USAF states they will not base awards on lowest price technically acceptable basis but will instead review best value and Fair and Reasonable Price evaluations. USAF will look at the following non-price factors breadth of the OEM products you are offering through your schedule or through your team; Relevant Experience; Socioeconomic Factor and subcontracting goals; and finally Supply Chain Risk Management.  Pricing factors will be based on the evaluation of a market basket; which include the most commonly ordered items under the BPA. Note of concern is that bidders must provide quotes for all the most commonly ordered products or face possible elimination from the BPA evaluation.

All products proposed must be awarded to you GSA IT 70 schedule or to a member of your teams’ schedule; No Open Market Items are permitted.

USAF anticipates awarding nine (9) BPAs to vendors or teams.

Most frequently ordered manufacturers include:

BPA Line Item One Data Center (Compute/Store) BPA Line Item Two End User BPA Line Item Three Network (Connect) BPA Line Item Four Radio Equipment
HPE Dell Cisco Motorola
APC HPI Extreme
Networks
Harris
Vmware Symantec Broadcom/
Ruckus/Brocade
 
Dell LG NetApp  
IBM Samsung F5 Networks  
  McAfee Juniper  

Locate the RFQ on your eBuy site.  If you need assistance with the response, building a team, or accessing your eBuy contact Coley at 210-402-6766 or by email at [email protected].

Is it Now Easier to Enter the Professional Services Schedule?

Is it Now Easier to Enter the Professional Services Schedule?

The Professional Services Schedule (PSS) is making it easier to win new schedules and new SINs. The General Service Administration 00CORP PSS program announced that an upcoming March 2019 solicitation will streamline the solicitation and remove barriers to entry for new and existing schedule holders. (more…)

TXMAS Temporarily Suspending New Offers

TXMAS Temporarily Suspending New Offers

The Texas State Procurement Division (SPD), which manages the Texas Multiple Award Schedule (TXMAS), has announced that “effective immediately, SPD has issued a hold on accepting all new TXMAS applications.”

SPD cannot provide a guaranteed date to re-opening the successful TXMAS program, but tentatively have stated they expect the suspension to last through March 14, 2019. Interested vendors should return to the site after March 1, when a determination will be made regarding the suspension.

Current proposals in review will remain in the review process. All new application packets will be rejected and returned.

The TXMAS program has had difficulties and long review cycles over the last few years when sweeping changes were implemented, including:

  • Introduction of the online TXSmartBuy purchasing portal
  • Reduction in Texas Contract Redundancies
    • removal of all Technology products and services, including ancillary technology services, conferring communication, and audio-visual solutions – those offering are supported under the TX DIR program (TX DIR)
    • Other Miscellaneous products and solutions provided under State Term contracts (Term)
  • A requirement of a Signed letter from authorized buyers, guaranteeing purchasing through the TXMAS program

The award review cycles for contracts have been pushed from six months to 18 months for some vendors.

TXMAS is a successful state, local, and education procurement vehicle that award multiple award contracts using other federal and state multi-year award contracts as a base for establishing product offerings and price reasonableness.

If you are interested in pursuing the TXMAS contracting vehicle or other government and cooperative purchasing vehicles, contact Coley for assistance.

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