Coronavirus Relief Options for Small Businesses

Coronavirus Relief Options for Small Businesses

Recently, much has been written regarding Coronavirus relief options for small businesses through traditional SBA funding and several new temporary programs established by the Coronavirus Aid, Relief, and Economic Security (CARES) Act. Important information about each program including the application process and qualifications can be found on the SBA’s website here.

The two primary relief options are the Economic Injury Disaster Loan (EIDL) Emergency Advance and the Paycheck Protection Program. Both programs are loan options and contain the possibility of forgiveness. Both programs also have restrictions on how the loan may be used. See SBA for more information on use requirements.

EIDL allows small businesses to receive a loan of up to $2 million ($25,000 unsecured) with an available grant advance of up to $10,000. This loan will be automatically deferred for 12 months with a term of up to 30 years and an interest rate of 3.75%. EIDL eligibility includes: 

  • Small Businesses started before January 31, 2020 Small Businesses (under 500 employees)
  • Sole Proprietors (under 500 employees)
  • Independent Contractors
  • Self-Employed Persons
  • Cooperatives (under 500 employees)
  • Employee Stock Ownership Plan (ESOP) (under 500 employees)
  • Tribal small business (under 500 employees)
  • Agricultural cooperative, aquaculture enterprise, nursery, or producer cooperative (under 500 employees)
  • Business with more than 500 employees but under SBA Size Standards
  • Private non-profit organization with IRS designation 501(c),(d), or (e) OR State evidence is a non-profit one organized or doing business under State law, or a faith-based organization. 

The Paycheck Protection Program is designed to provide up to 8 weeks of payroll and other business expenses. Loans may be requested for up to $10 million. Loan will be deferred for six months with a two-year repayment term and 1% interest rate. Loan eligibility requirements include: 

  • Small Businesses started before February 15, 2020
  • Any small business concern that meets SBA’s size standards (either the industry based sized standard or the alternative size standard)
  • Any business, 501(c)(3) non-profit organization, 501(c)(19) veteran organizations, or Tribal business concern (sec. 31(b)(2)(C) of the Small Business Act) with the greater of: 500 employees, or
  • That meets the SBA industry size standard if more than 500
  • Any business with a NAICS Code that begins with 72 (Accommodations and Food Services) that has more than one physical location and employs less than 500 per location
  • Sole proprietors, independent contractors, and self-employed persons 

Loan Forgiveness

In regard to the PPP, the loan will be fully forgiven if the funds are used for payroll costs, interest on mortgages, rent, and utilities (due to likely high subscription, at least 75% of the forgiven amount must have been used for payroll). Forgiveness is based on the employer maintaining or quickly rehiring employees and maintaining salary levels.  Forgiveness will be reduced if full-time headcount declines, or if salaries and wages decrease. To apply for loan forgiveness each recipient should be prepared to submit a written request to your lender. The lender will have 60 days to reply. The written request should include documents verifying full time equivalent employees, employee pay rates, payments on eligible mortgage, payments on eligible lease, and payments on utilities.

Forgiveness regarding the EIDL Emergency Advance program is limited to the grant advance itself of up to $10,000 which must be used for prescribed business expenses.

During the rollout of these programs, one thing is clear. No one has all the answers. There is a great deal of confusion regarding the two most talked about programs the EIDL Emergency Advance and the Paycheck Protection Program (PPP). Please keep in mind that available information is changing rapidly and is often based on the current understanding or interpretation of these programs. It can and likely will continue to change. Rather than speculate as to the answers to some of the more difficult questions surrounding each program, a better approach is to focus on some practical steps you can take to help these programs work for your business most effectively. 

First, Get Educated 

Consult with your lawyers, CPAs, Bankers and Financial Advisors regarding these programs as soon as you are able. There are daily webinars put on by various groups including local and regional SBA offices, Chamber of Commerce groups, CPA firms, Banks and Law firms. One excellent way to engage the latest information about these programs is through social media. Many local and regional SBA offices are very active relaying educational opportunities and available information via their official twitter accounts.

Do Not Delay

Once you have identified a broad understanding of how these programs may help your business DO NOT DELAY. The PPP for small businesses was made available April 3rd and many have already submitted applications. Independent Contractors and Self-Employed Individuals may begin applying April 10th, 2020.

Make sure that you are being proactive in applying as soon as you can if you have not already applied. The EIDL Emergency Advance application can be found on the SBA’s website here.

For the PPP, you will need to apply through a bank or credit union. The SBA and others are recommending, if possible, you work with a banker that you have an existing banking relationship with. You can find eligible lenders here.

Organization is Key

Having strong paper and digital business records will help you tremendously during the application process but also be vigilant about keeping records during and after the loan application process as well. It is important to ask lots of questions, take good notes and get any clarification in writing. It is confirmed that businesses will be asked to provide their NAICS code and DUNs number as part of the application process. These can easily be accessed by Coley customers here under the Entity Dashboard.

Follow Up

Be patient but not too patient. Throughout the rollout of these programs, it is clear the timing of funding is delayed. It is also clear that the businesses that have followed the steps laid out above will have the most success. Regarding the EIDL Emergency Advance and the Paycheck Protection Program, it may be necessary to engage daily. The SBA has determined that the loans will be distributed on a first come first served basis. Do not be afraid to regularly follow up with the SBA and/or your Banker directly. The adage “The squeaky wheel gets the grease” certainly applies here. Again, it is prudent to utilize the social media accounts of local and regional SBA offices, Chamber of Commerce groups, CPA firms, Banks and Law firms for the latest updates, information, and interpretations of these programs.

Are Other Programs a Better Option for Your Business?

Do not overlook the lesser talked about SBA Express Bridge Loans and SBA Debt Relief programs. For those that qualify, there is evidence that these programs applications are being processed more quickly, simply because they have been less utilized during the Coronavirus event. For example, for businesses that qualify, the SBA Express Bridge Loan may be a more efficient and more realistic program to quickly access funds as an alternative to the EIDL  that is currently plagued with delays and confusion. Specifics about this program can be found here.

Seeking debt relief instead of a new loan from a program like the Paycheck Protection Program may be an option for many small businesses. The SBA Debt Relief program may be an excellent choice for those businesses that already have current SBA 7(a), 504 or microloans. More specific information about this program can be found here.

Additionally, there are some general indications that businesses that qualified for SBA funding before the expansion of the qualifications under the recent CARES Act may have an advantage in tapping these resources most effectively. Businesses with an existing relationship with the SBA or businesses with a profile familiar to the SBA could experience smoother application processes across the board. More information about one such qualifying business, SBA 7(a), can be found here.

One Last Important Tip for Our Coley Customers – Action Item! 

Business owners around the country may have recently had their identities compromised through the SBA website intended to help them during the Coronavirus event. There is no confirmation yet on how many business owners could have been exposed; the SBA is only saying a “limited number”. One thing is for sure, if you feel you may have been exposed, it is paramount that you take action now. The SBA disaster relief loan application process requires both a personal and business credit check. For small business owners, there is currently no mechanism for freezing a business credit file. Normally a personal credit freeze would be appropriate if you believe you have been compromised, but a freeze now could delay or hinder your ability to complete personal identity verifications and personal credit checks required for the SBA disaster funding opportunities. So, what should you do? Diligently monitor your personal and business credit to protect your identity against potential fraud. There are indications that fraud has increased since the Coronavirus event with reports of increased phishing scams, fraud-focused phone calls and even app stores flooded with data-leaking apps specifically targeting small businesses seeking SBA loans under the new programs Credit monitoring services are offered through the 3 major credit bureaus as well as other commercial providers.

Coley GCS will continue to monitor and will publish more updates as they become available.

 

 

Is COVID-19 Causing You Government Contract Delays?

Is COVID-19 Causing You Government Contract Delays?

With COVID-19 spreading to more people daily and with the emergency declarations
that have been enacted, it’s likely that your business will be impacted as well. As a government contractor, your business has contractual obligations that could become difficult to fulfill in this environment. As such, you should be aware of contract clauses that may provide you relief in the form of excusable delays and compensable delays in performance.

Excusable delays protect contractors from termination for default  and bad contractor performance reports; both of which can effectively put a contractor out of business.  

The first thing to do is to determine which of the federal acquisition regulation clauses are in your contract and whether the agency’s policies during the Coronavirus pandemic are impacting your ability to deliver. If so, read the clauses closely and take action to preempt possible delays or default on your contract by identifying delays and assessing any additional costs associated with the delays. Then, notify the contracting officer immediately of your requests for equitable adjustments (REAs) or extensions to performance periods. Below are a FAR clauses that are related to unexpected delays.

Excusable Delays

FAR 52.249 – 14

 “the Contractor shall not be in default because of any failure to perform this contract under its terms if the failure arises from causes beyond the control and without the fault or negligence of the Contractor. Examples of these causes are

  1. acts of God or of the public enemy,
  2. acts of the Government in either its sovereign or contractual capacity,
  3. fires,
  4. floods,
  5. epidemics,
  6. quarantine restrictions,
  7. strikes,
  8. freight embargoes, and
  9. unusually severe weather.

In each instance, the failure to perform must be beyond the control and without the fault or negligence of the Contractor. Default includes failure to make progress in the work so as to endanger
performance.”

Compensable delays allow contractors to be compensated for lost or excess costs of delays.

 Suspension of Work 

FAR 52.242-14

(a) The Contracting Officer may order the Contractor, in writing, to suspend, delay, or interrupt all or any part of the work of this contract for the period of time that the Contracting Officer determines appropriate for the convenience of the Government.

(b) If the performance of all or any part of the work is, for an unreasonable period of time, suspended, delayed, or interrupted

(1) by an act of the Contracting Officer in the administration of this contract, or 

(Get full Suspension of Work clause here)

Stop-Work Order

FAR 52.242-15 

(a) The Contracting Officer may, at any time, by written order to the Contractor, require the Contractor to stop all, or any part, of the work called for by this contract for a period of 90 days after the order is delivered to the Contractor, and for any further period to which the parties may agree. The order shall be specifically identified as a stop-work order issued under this clause. Upon receipt of the order, the Contractor shall immediately comply with its terms and take all reasonable steps to minimize the incurrence of costs allocable to the work covered by the order during the period of work stoppage. Within a period of 90 days after a stop-work order is delivered to the Contractor, or within any extension of that period to which the parties shall have agreed, the Contracting Officer shall either—

(1) Cancel the stop-work order; or

(2) Terminate the work covered by the order as provided in the Default, or the Termination for Convenience of the Government, clause of this contract.

(Get full clause here)

Protect your company and survive through the quarantine. Speak with your COR early and work with them to ensure your success.

If you require assistance, please contact Coley at [email protected].

Guide to Prepare for Mass Modifications

Guide to Prepare for Mass Modifications

GSA Interact has released a helpful guide to prepare for the upcoming mass modification being released this Friday: https://interact.gsa.gov/document/prepare-upcoming-mass-mod-13120-mass-mod-checklist

GSA covers three central topics to what to consider before, during, and after signing the mass modification.

Before You Sign the Mass Modification

To summarize, GSA lists Six Things to do before you sign the Mass Mod

  1. Review the SIN Mapping Available Offerings Attachment.
  2. Review beta.sam.gov and verify that your company has the appropriate NAICS listed.
  3. Review the terms and conditions under the Mass Mod (link).
  4. If you take any exceptions to the standard T&C, you will need to catalog and address them during the mass mod process.
  5. If you contract is in the process of being renewed for an option period, speak with your contracting before accepting the mass modification
  6. If you have any pending Add or Delete SIN mods, contact your contracting officer as this modification will either need to be processed and awarded or withdrawn/rejected.

While Signing the Mass Mod

  1. You must respond to every clause.
  2. A mass mod will need to be completed for every contract you have on GSA
  3. Your contract number and period of performance will not change.
  4. The products and services on your contract will not change.

After you Sign the Mass Mod

  1. Verify your company is visible in eLibrary under the MAS vehicle
  2. Confirm your that SINs have migrated
  3. If you have legacy SINs that map to multiple new SINs, work with your CO to delete any new SINs that you do not need
  4. All contractors will need to update their GSA FSS Price list and product files with the latest SINs and terms & conditions. Files and products must be uploaded through the SIP or EDI programs to be active on eLibrary/Advantage. If you are affected by the migration in #3, you will be required to create and submit a new SIP files to properly align SINs. SIP/EDI Instructions
  5. Update any websites and marketing materials to include the new Schedule name, Schedule number, Large Category, Subcategory, and SIN structure (e.g., company website, capability statements, quote templates, etc.)

Understand that GSA is restricting any new Add or Delete SIN modification actions in the eMod system under March.

For a complete MASS Mod Timeline see below:

Mass Modification Release Date Legacy Schedule Number
Friday, 1/31/20 03FAC, 23V, 36, 48, 51V, 58I, 599
Monday, 2/3/20 00CORP
Tuesday, 2/4/20 00CORP continued
Wednesday, 2/5/20 70
Thursday, 2/6/20 70 continued
Friday, 2/7/20 71,71 IIK, 72, 73,56, 66, 67
Monday, 2/10/20 736, 738X, 75, 751
Tuesday, 2/11/20 76, 78, 81 I B, 84 

If you need assistance with the transition to the MAS contract, contact the experienced advisors at ColeyGCS.

MAS Consolidation Updates

MAS Consolidation Updates

As GSA moves from 24 separate schedules to one Multiple Award Schedule (MAS) they are beginning to release some concrete dates.  For an updated timeline, visit our “Guide to Prepare for MASS Modifications.

The MAS transition has always been defined as a three-phase process beginning October 01, 2019 and stretching through July 2020, but the phase II and II dates were nebulous. Here are the dates as they have been shared with us from GSA Contracting Officers:

PHASE II – Accepting MAS Solicitation

  • January 31 – Mass modifications accepting the latest MAS solicitation will be sent to legacy contract holders. Every contract will need to accept the mass the modification. They are stating that these
    modifications will be sent in batches and make takes days or weeks to reach everyone.
  • January 31 – Modifications to add a new SIN through eOffer will be removed. New SIN additions will be placed on hold until
    March 14th.  SIN additions submitted prior to that deadline will still be considered though there may be a higher likelihood of rejection

PHASE III – Consolidating Legacy Contract to the MAS Contract>

  • July 01 – (targeted start date) Legacy contracts will be asked to work with the MAS Program Management Office (PMO) and the affected Authorizing Official (AO); likely your Procurement Contracting Officers (PCO), to develop a transition plan to consolidate multiple contracts.

Each Vendor will have the option to determine which schedule should be the primary and accept the SINs of the other schedule. The timeline for each transition will be determined on a case-by-case basis.

Legacy vendors with only one schedule will have a much easier time of transition, as acceptance of the mass modification is the primary action.

  • NOTE – It is possible to get ahead of the consolidation before July 2020 by completing add SIN modifications after the March 14th date to include SINs you have on other schedules onto
    your preferred schedule. It is yet to be seen if you will be required to complete the modification requirements as if they are newly added SINs, meaning providing substantiation and past performance or if discounts will be re-negotiated. Once you add all relevant SINs to your primary contract, you will then cancel the other contract.

This will be a harried time and our conversations with PCOs have stated that they are not 100 percent certain of ease of transition will be moving forward. It is important to understand what you should consider when determining the best schedule to keep.

We will be providing modifications, guidance and training for all Coley customers. If you need assistance, contact Coley today.

GSA MAS Consolidation Mass Modifications Scheduled for January 31, 2020

GSA MAS Consolidation Mass Modifications Scheduled for January 31, 2020

GSA combined 24 separate GSA schedules into one large schedule titled the Multiple Award Schedule (MAS) October 01, 2019. All new offers submitted after that date were submitted against the MAS solicitation.

 For legacy contractors, GSA is planning on releasing the MAS consolidation schedule mass modification, January 31. https://www.coleygsa.com/guide-to-prepare-for-mass-modifications/#timeline

This mass modification will allow existing schedule holders to accept the terms of the new MAS schedule and begin the process of migrating current SINs to the new SIN system. The modification will also allow vendors with multiple schedules to begin the planning and processing of migrating those schedules into one schedule combining all services and products.

 GSA has stated that they anticipate the migration of legacy contractors to the MAS schedule to happen from January to July; to allow time to migrate all schedule together.

 Vendors with multiple schedules will be required to accept the mass modification for all schedules and then determine which schedule will be the predominate schedule.

 Important items to consider when determining the primary schedule for consolidation:

  • Remaining contract duration,
  • Transactional Data Reporting vs Commercial Sales
    Practices compliance,
  • Preponderance of Sales
  • Familiarity with the contracting officer and
    their modification preferences, timeliness.
  • Which contract has open task order
  • Among others

 eBuy will also be updating their systems to all opportunities to be found under legacy and new SINs.

 There are many changes coming and we’ll help guide you through this process. If you have any questions, please call your advisor directly.

 If you are not a current Coley GCS client, we can offer you the level of support that best fits your needs. Please call us at 210-402-6766 or email [email protected] to assist.

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…)

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