GSA Releases Final Solicitation for ASTRO IDIQ

GSA Releases Final Solicitation for ASTRO IDIQ

GSA published the final solicitation for their next large IDIQ, ASTRO. ASTRO will be one of the largest IDIQ’s in the coming years, including up to 450 contractors and an undefined ceiling. ASTRO will cover ten distinct pools covering manned, unmanned, and optionally manned platforms and robotics.

GSA will evaluate vendors using a self-scoring matrix. The scoring will cover relevant experience that includes locations, Cost Reimbursement Project, Subcontracting, OCUNS, Functional projects, and CPARS. Additional scoring factors will include cybersecurity certifications, ISO, and internal systems (purchasing, management, estimating, etc.).

The ten pools include the following areas


  • Function: Performance of Data Operations including all data collection, processing, exploitation, and dissemination activities associated with manned, unmanned, and optionally manned platforms and robotics supporting mission performance. This includes traditional labor services as well as “as a service” support.
  • NAICS: 541990 – All Other Professional, Scientific, and Technical Services
  • Small Business Size Standard: $16.5 Million


  • Function: Mission Operations includes performance of operational services not included in Data Operations associated with manned, unmanned, and optionally manned platforms and robotics supporting mission performance. This includes traditional labor services as well as “as a service” support.
  • NAICS: 541990 – All Other Professional, Scientific, and Technical Services
  • Small Business Size Standard: $16.5 Million


  • Function: Maintenance, repair, and overhaul of manned, optionally manned, and unmanned aircraft.
  • NAICS: 488190 – Other Support Activities for Air Transportation
  • Small Business Size Standard: $35 Million


  • Function: Maintenance, repair, and overhaul of manned, optionally manned, and unmanned ground platforms and industrial machinery.
  • NAICS: 488999 – All Other Support Activities for Transportation
  • Small Business Size Standard: $8 Million


  • Function: Maintenance, repair, and overhaul of manned, optionally manned, and unmanned space platforms.
  • NAICS: 488190 – Other Support Activities for Air Transportation
  • Small Business Size Standard: $35 Million


  • Function: Maintenance, repair, and overhaul of manned, optionally manned, and unmanned maritime platforms.
  • NAICS: 336611 – Ship Building and Repairing
  • Small Business Size Standard: 1,250 employees


  • Function: Systems integration, improvement, and/or engineering associated with manned, unmanned, and optionally manned platforms.
  • NAICS: 541330 – Engineering Services
  • Small Business Size Standard: $41.5 Million (based on the 541330 exceptions)


  • Function: All R&D associated with manned, unmanned, optionally manned, and counter Unmanned Systems (UxS) platforms
  • NAICS: 541715 – Research and Development in the Physical, Engineering, and Life Sciences (except Nanotechnology and Biotechnology)
  • Small Business Size Standard: 1,000 Employees


  • Function: All support services (except training) required for successful execution of a product, program, project, or process regarding platforms and robotics for land, air, sea, or space; the planning necessary to support operational missions; and the analysis of the results of an operational mission.
  • NAICS: 541990 – All Other Professional, Scientific, and Technical Services
  • Small Business Size Standard: $16.5 Million


  • Function: All training (the providing of instruction) services required for successful execution of a product, program, project, or process regarding platforms and/or robotics for land, air, sea, or space.
  • NAICS: 611699 – All other Miscellaneous Schools and Instruction
  • Small Business Size Standard: $12 Million

ASTRO is a DoD contract operated their Federal Systems Integration and Management Center (FEDSIM), however, GSA will be administering the contract.

Proposals are due no later than 4pm Central Daylight Time (CDT) on October 30, 2020

GSA eBuy Rolls Out Updates; New SIN Subgroups

GSA eBuy Rolls Out Updates; New SIN Subgroups

GSA eBuy Rolls Out August 2020 Update

On August 1st, 2020, the General Services Administration had rolled out an eBuy update that allows contractors to select subgroups to some popular SINs awarded on contract.

Customers are still able to release opportunities by GSA’s defined SIN and contractors who meet the criteria will receive them.  Now that most SINs have been consolidated under the new GSA Schedule Multiple Award Schedule, these opportunities can also be filed under more precise subcategories that fall under select SINs.

Contractors are encouraged to view their profiles and further define their SIN’s subcategories for greater precision.  Selecting (or de-selecting) subcategories should increase the likelihood that the contractor will receive an opportunity that is relevant the awarded products and services that are awarded under the GSA Schedule contract.  Contractors should monitor the intake of opportunities to determine if the current subcategory selection meets their needs.

Category 541611

Customers are also able to include one or more of the following complimentary SINs to an opportunity: ANCILLARY, ANCRA, OLM, and 238910.  This will allow contractors to include these items and services on an eBuy quote as appropriate. (check your contract for applicability).

And finally, GSA eBuy will no longer display GSA Legacy Schedules in eBuy.  All contractors should have accepted the MAS Consolidation Mass Mod (A812), otherwise the eBuy account and other GSA Services may be subject to suspension until the mass mod has been accepted.

Contractors are able view/select subgroups by logging in to the GSA eBuy account.  By clicking on the vendor profile, contractors will be able to see the “modify subgroups” button and will allow for subgroup management as shown in the table below.

Contractors who need help with updates stemming from MAS Consolidation, please reach out to Coley GCS at [email protected] or directly at 210.402.6766.

SIN Subgroups Management Table:

SIN Description
561210FAC Complete Facilities Maintenance & Management
  Elevator / Escalator Inspection Service (Requires proper Certifications & Licenses)
Elevator / Escalator Maintenance Service (Requires proper certifications & Licenses required)
Facilities Consulting, Assessment and Planning
Facilities Management
HVAC Maintenance: Boilers, Chillers, Refrigeration, etc.
Janitorial Services
Maintenance of Fire Alarm Systems (Requires proper Certifications & Licenses required)
Maintenance of Fire Suppression Systems- Water Based (Requires proper Certifications & Licenses)
Maintenance of Fuel Facility System
Maintenance of Renewable Energy Systems
Maintenance of Utilities
541690E Energy Consulting Services
  Building Commissioning Services
Energy Audits
Energy Services Consulting
Metering Services
Renewable Energy
Resource Efficiency Management (REM) Services
Training on Energy Management
Water Conservation
332311P Pre-engineered and prefabricated Buildings and structures for storage
  In-Plant Solutions
Professional Facility Solutions
Outdoor Shelter and Security Shelter Solutions
Rapid deployment solutions for for Military, Disaster/Emergency Response
Restroom, Shower, and Laundry Solutions
Storage Solutions, SCIFs
532490P Lease/Rental of Pre-Engineered/Prefabricated Buildings and Structures
  Lease/Rental of Pre-Engineered/Prefabricated Buildings and Structures
Lease/Rental of Pre-Engineered/Prefabricated Restrooms and Utility Rooms
333241 Food Preparation Equipment
  Concession Equipment
Cooking Equipment
Food Measuring and Testing Devices
Food Preparation Equipment
Food Preparation and Storage Smallwares
Food Service Storage Racks and Cabinets
Food Serving and Merchandising Equipment
336999 Food Center Concepts
  Food and Beverage Dispensing Equipment
Food Service Carts and Holding and Transport Equipment
Hot and Cold Food Counters
333318F Floor Care Cleaning and Equipment
  Floor Machine
Sweepers and Scrubbers
Vacuum Cleaner Canister, Upright, and Portable
335999 Power Distribution Equipment
  Alternative and Solar Energy Solutions
Motors and Controls
Portable Light Towers
Power Distribution Units
Surge Protection
Switchgear, Panelboards, Switchboards, Load Centers, Metering
Uninterruptible Power Supplies
325612 Disinfectants, Sterilants and Deodorizers
  Automotive cleaners and polishers
Permanent/Disposable dispenser housing and refills for odor control and sanitizing of surfaces
Sanitizers for Food Handling Areas
Sterilants, Surgical Scrubs, and Specialized kits for blood, serum, and/or associated body fluid spills
325998 Chemical Additive
  Not listed
325611 Cleaning Products
  Biodegradable Cleaner/Degreaser (Solvent Based) Non-Phenolic and Non-petroleum
Biodegradable Cleaner/Degreaser (Water Based) Non-Phenolic and Non-Petrolemm – Products approved by USDA for Food Handling Areas
Cleaning Chemical Dispensing Equipment and Systems
Cleaning Chemicals used with Dispensing Systems
Cleaners/Degreasers – (Water and/or Solvent Based Detergent)
Cleaner/Degreasers and Polishes – (I,I,I Trichloroethane CFC Replacement for Industrial/Electrical Applications)
Sorbents – Marine Usage, Type III Non-water soluble
Sorbents – Non-Marine Usage Type I for Non-hazardous & Non-toxic Organic Spill
Sorbents – Non-Marine Usage Type II for Hazardous and Toxic Organic Spills
54151HACS Highly Adaptive Cybersecurity Services (HACS)
  Cyber Hunt
High Value Asset (HVA) Assessments
Incident Response
Penetration Testing
Risk and Vulnerability Assessment (RVA)
517312 Wireless Mobility Solutions
  Enterprise Mobility Management (EMM)
Internet of Things (IoT)
Mobile Application Vetting
Mobile Backend-as-a-Service (MBaaS)
Mobile Identity Management
Mobile Threat Protection (MTP)
Mobility-as-a-Service (MaaS)
Other/Mobile Services
Other Mobility End-Point Infrastructure – Mobility infrastructure
Telecom Expense Management (TEM)
Wireless Carrier Services
54151S Information Technology Professional Services
  Auto. Info. System Design & Integration
IT Systems Analysis Services
IT Systems Development Services
Programming Services
Automated News, Data and other Info. Services
CAD/CAM Services
Desktop Management
Information Assurance
IT Backup and Security Services
IT Data Conversion Services
IT Facility Operation and Maintenance
IT Network Management Services
54151ECOM Electronic Commerce and Subscription Services
  E-Mail Services
Internet Access Services
Navigation Services
Other Data Transmission Services
Value Added Network Services
511210 Software Licenses
Office Productivity
Operating Systems
Programming (Commercial Off the Shelf (COTS))
Software Utilities and Tools
Threat Protection
Business Mgmt
Electronic Commerce/Internet
Financial Management
33411 Purchasing of New Electronic Equipment
  Airborne Radar Equipment
All in One Printers
Audio Visual/Conference Room Equipment
Backup Power/UPS
Broadcast Band Radio
Cables and Interfaces
Computer Monitors
Digital Cameras
End User IT Accessories
End User IT Peripherals
Fiber Optic Equipment
Hyperconverged Integrated Systems
Keyboard Video Monitor (KVM) Switches
Laptops (inc. Rugged)
Large Format Displays
Microwave Radio Equipment
Network Equipment
Network Printers
Radio Base Stations
Radio Chargers
Radio (inc. LMR) Handhelds
Radio Navigation Equipment/Antennas
Radio Repeaters
Radio Transmitters/Receivers, Airborne
Radio Trunking System
Satellite Communications Equipment
Security Appliances
Software Defined Network Equipment
Storage – Memory, Solid State (SSD), Software Defined (SDS), Network Attached (NAS), Storage Area Network (SAN)
Tablets (inc. Rugged)
Thin Clients
Tower/Small Form Factor/Micro/Mini Computers
Vehicle Radio Units
Video/Media Distribution Equipment
Video Teleconferencing (VTC)
Wireless LAN Equipment
339940OS4 OS4 Office Products and Supplies 
  Binding and Filing
Calendars and Personal Organizers
Computer Accessories
Desk Supplies (calculators, pens, paper clips, portfolios, tape, stamp pads, etc.)
Mailing and Shipping Supplies
Office Furnishings (clocks, easels, frames, stools, etc.)
Paper Products (copy paper, notepads, labels, etc.)
Toner Cartridges
541611 Management and Financial Consulting, Acquisition and Grants management Support, and Business Program and Project Management Services
  Acquisition/Grant Management Support
Actuarial Services
Customer Survey Services
Facilitation Services
Financial Consulting Services
Financial, Economic and Regulatory Analysis Support
Management Consulting Services
Program/Project Management Support
Strategic Planning
562112 Hazardous Waste Disposal Services
  Recycling Services
541211 Auditing Services
  Contract Audits
Performance Audits
Recovery Audits
Transportation Audits
522310 Financial Advising, Loan Services and Asset Management Services
  Financial Asset Advisory Services
Loan Servicing
541330ENG Engineering Services
  Chemical Engineering Services
Civil Engineering
Construction Management Services
Electrical Engineering Services
Engineering Consulting Services Relating to Real Property
Fire Protection Engineering Services
Mechanical Engineering Services
Space Launch Integrated Services (SLIS)
Systems Engineering
562910REM Environmental Remediation Services
  Environmental Reclamation Services
Environmental Remediation Services
541930 Translation and Interpretation Services
  Exercise Role Players
Interpretation Services
Language Services for the Visual and Hearing Impaired
Linguistic Analytical Support Services
Translation Services
541614 Deployment, Distribution and Transportation Logistics Services
  Deployment Logistics
Distribution and Transportation Logistics Services
541620 Environmental Consulting Services
  Archaeology and Cultural Resource Services
Environmental Management Systems (EMS)
NEPA Related Services
561621H Harbor/Waterfront Security Products and Services and Professional Marine Security Services
  Not listed
339113LAB Laboratory Equipment and Products
  Not listed
334515 Diagnostic, Measuring and Testing Equipment
  Not listed
334516 Analytical Instruments
  Biomedical And Industrial Particle Counting, Sorting Apparatus, Systems, and Related Chemistries
Biomolecule Analyzers Synthesizers
Blood Cell Analyzers For Clinical Hematology And Related Chemistries
Elemental Analyzers
Gas Chromatograph (GC) And Chromatograph/Mass Spectrometer (GC-MS) Systems
Liquid Chromatographer (LC) And Liquid Chromatographer/ Mass Spectrometer (LC-MS) Systems
Thermal Analysis
332439 Shipping, Cargo, Freight, and Storage Containers
  Not listed
Smart Buying for America Emphasizes Small Business Procurements

Smart Buying for America Emphasizes Small Business Procurements

With the increasingly negative economic impact of the COVID-19 pandemic, the federal government has detailed its efforts to support an effective economic recovery in an effort referred to as “smart buying for America.”

The Executive Office of the President sent a memo to the various heads of executive departments and agencies detailing the newest initiatives. The goal is to simplify the procurement process and give agencies access to a wider range of companies. (more…)

FPDS is Moving!

FPDS is Moving!

In keeping with initiatives created under the 21st Century Integrated Digital Experience Act (21st Century IDEA), it was recently announced that Contract Data Reports for Federal Procurement Data System (FPDS) users are being moved to  FPDS is a free reporting module which tracks all federal contracts of over $10,000.  The 21st Century Integrated Digital Experience Act mandates new or redesigned government agency digital services, including websites, forms and applications must be: accessible and usable, based around user needs and tasks, consistent in appearance, securely hosted and connected, searchable and mobile friendly. (more…)

President’s Executive Order Repeals “Right of First Refusal” on Federal Contracts

President’s Executive Order Repeals “Right of First Refusal” on Federal Contracts

On October 31, 2019 President Donald Trump signed an Executive Order (Executive Order on Improving Federal Contractor Operations by Revoking Executive Order 13495), which repeals the previous obligation of successor Federal contractors to offer qualified predecessor employers’ employees the right of first refusal in positions at the same work location. This repeals Executive Order 13495, which had been signed by President Obama on January 30, 2009.

The repeal removes the requirement to offer the right of first refusal to incumbent employees under the assumption by a new Federal contractor of any Federal contract subject to the provisions of the Service Contract Act.

The Executive Order further orders the “the Secretary of Labor (Secretary), the Federal Acquisition Regulatory Council, and heads of executive departments and agencies shall, consistent with law, promptly move to rescind any orders, rules, regulations, guidelines, programs, or policies implementing or enforcing Executive Order 13495.”

At Coley, offer our clients up-to-date, comprehensive, and informed guidance regarding all matters pertaining to the hiring provisions under Federal contracts, including all matters pertaining to the Service Contract act requirements and compliance.

US & Hong Kong Tensions Threaten Trade Status

US & Hong Kong Tensions Threaten Trade Status

China has approved stricter national security measures against citizen of Hong Kong., The US fears the new security measures increase the risk that sensitive US technology can be obtained by mainland China and the US Commerce Department has already approved suspending special export licenses granted to Hong Kong.

In May, Trump announced he wanted the administration to begin removing special trade privileges provided to Hong Kong. It is likely that the restriction on exporting defense and technology products to Hong Kong will expand to affect import trading as well, unless there is an immediate withdraw of China from Hong Kong.

If Hong Kong loses its trade status it will lose its place as a designated country under the Trade Agreement Act (TAA). Losing status as a designated country will have a ripple effect that will require all resellers with products manufactured in Hong Kong to find new sources in complaint countries or remove them from your GSA and other Federal Contracts.

If you offer products from Hong Kong, we recommend that you begin to search for alternative manufacturing sources. We have a blog that identifies all TAA designated countries.

Once a source is found and a partnership is created, it would become necessary to update your existing contracts with the newly sourced products or software. GSA modifications can take time to develop and have approved, so watch the tensions closely and consider the possible alternatives.

We have completed thousands of modifications of the last 20 years and can assist you with changes to your GSA schedule. If you need assistance or have questions contact Coley at [email protected].

Non-TAA Items Now Available on Federal Supply Schedules

Non-TAA Items Now Available on Federal Supply Schedules


UPDATE: An addendum was released that extends the applicability date of SPE Memorandum SPE-2020-11.  Originally 7/1/2020, the applicability date was extended to 8/1/2020.

GSA has once again issued another addendum to this authority and will extend the date of applicability to 11/30/2020.  As directed with the original applicability date, applicable items on contract will need to be removed on this date as well.

Contractors who have added non-TAA products to their contracts may have already been receiving email checkups from GSA’s Internal Audit and Compliance Branch and Supplier Accountability and Acquisition Support Branch.  GSA is sending this follow up to ensure that contractors have a healthy stock of items and asking for any issues that contractors may be aware of.

With COVID-19 working its way throughout our nation, industries are coming together to help combat the virus.  From first responders to support teams, everyone is working together tirelessly to help alleviate this situation, and our Government agencies have been rapidly deploying solutions in support of COVID-19 relief efforts.

The General Services Administration (GSA) is one of the many Federal agencies looking to have a tremendous impact in helping those in need.  Since President Trump declared a National Emergency on March 13, and with all 50 states under a major disaster declaration for the first time in history, GSA Schedule contract holders have the ability to be placed at the forefront of support and can effectively assist all types of government (GSA FSS eligibility).

On April 3, 2020 General Services Administration released a memorandum that allows GSA Schedule contract holders to add non-TAA (Trade Agreement Act)  items from select Federal Supply Classes (FSC) onto the Federal Supply Schedule.  This unprecedented change temporarily adds exception to the government’s Trade Agreements and Buy American Statues by allowing contractors to add non-TAA items (excluding embargo nations such as Cuba, Iran, Sudan, Burma, and North Korea per FAR subpart 25.7) to the GSA Schedule with a unique contract modification. Once awarded, State, local, and Federal government agencies alike will be able to acquire items without the need for non-availability determinations.

Only the following items from select FSCs can be added at this time:

FSC General Products Purchased Determination Applicability Begin Date Determination Applicability End Date (*Updated)
FSC 4240 N95 masks 4/3/2020 *8/1/2020
FSC 6810 Sodium Hypochlorite (bleach) 4/3/2020 *8/1/2020
FSC 6840 Disinfectants – includes cleaners, sprays, and wipes 4/3/2020 *8/1/2020
FSC 7930 Cleaners – including sanitizing surface and floor cleaners 4/3/2020 *8/1/2020
FSC 8520 Hand sanitizers, soaps and dispensers 4/3/2020 *8/1/2020

GSA has released specific guidance and templates to use when submitting your modification.  Items will have to be removed from GSAAdvantage! and the Federal Supply Schedule contract once the applicability end date arrives

Be advised that the non-TAA exceptions are in support of COVID-19 efforts and for the predetermined Federal Supply Classes listed above.  52.225-5 Trade Agreements will still apply in all other conditions (list of TAA approved countries) and all other terms, conditions, and acquisition procedures will remain in effect.

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.



CARES Act Allows Payments to Contractors When They Can’t Work

CARES Act Allows Payments to Contractors When They Can’t Work

Coley has received several inquiries from our Federal contracting community as to how to recoup revenue lost as a result of being unable to fulfil contractual obligations due to the work interruption caused by the COVID-19 national emergency.  Section 3610 of the Coronavirus Aid, Relief, and Economic Security Act CARES Act, signed on March 27, contains provisions that apply to contractors unable to complete their contractual obligation due to work stoppage.  If a Federal contractor’s employees cannot work on a Federal Contract due to the COVID-19 pandemic, the contractor may be entitled to relief from contractual obligations and continue to receive payment.

The Office of Management and Budget (OMB) Memorandum M-20-19, issued on March 20, 2020 recognized the disruption that could be caused by work stoppages and suspended payments to Federal contractors in response to the COVID-19 national emergency.  The memorandum instructed Federal contracting personnel to “feel fully empowered to use acquisition flexibilities” during the national emergency.

Building on this need for flexiblity, Section 3610 if the CARES Act provides funds that allow contracting officers to reimburse contractors at the minimum applicable contract billing rates not to exceed an average of 40 hours per week in order to help contractors keep its employees or subcontractors in a ready state to resume work.

The limitations on the funds and contractual relief are that employees (or subcontractors) working on a Federal site that has been ordered not to work onsite, but their work cannot be performed remotely during the national emergency.  The other limitation is that the funds and contractual relief expire on September 30, 2020.

We all know how important it is to be informed in these times and of the many challenges that Federal contractors face, professionally and personally, during this national emergency.  Coley has continued to work without interruption to support its clients and will continue to share developments that affect our clients and the Federal contracting community.

COVID 19 Impacting Commercial Markets But Government Contracts Still Being Awarded

COVID 19 Impacting Commercial Markets But Government Contracts Still Being Awarded

COVID 19 is wreaking havoc in the commercial marketplace and negatively affecting everything from airlines to local restaurants, and everything in between. As a government contractor, I’ve been watching the government acquisition flow over the past couple of months and it appears that the government remains open for business and continuing to award contracts.

Most government contracting officers are now working from home but are able to continue doing their jobs. Obviously, some of their purchases have changed based on the changing priorities, but overall, the government continues to award contracts at the same pace they did two months ago.

If we see any slow down over the next month or two it will only add to the number of contracts that need to be awarded this summer since budgets must be spent before the September end-of-year.

Contractors should continue pursuing target opportunities and position themselves for the surge of new contract awards that will undoubtedly happen this summer.

If you’re new to government contracting or looking for ways to expand your government business, consider signing up for our Federal Market Acceleration Program (FedMAP™). Coley’s FedMAP™ Program is the first hands-on, peer-advisory cohort training program available to government contractors focused on accelerating a company’s entry or expansion into the Federal Market by leveraging the experience of a coach; knowledge and support of peers; and a proven online curriculum. Our program translates learning into action that results in accelerated contract wins.

Invest in your future now and learn more at

GSA Provides 60-Day Extension

GSA Provides 60-Day Extension

You probably have many things on your mind right now other than renewing your registration. Given that business and government alike are focused on responding to the Coronavirus/COVID-19 national emergency, the General Services Administration (GSA) has announced that it will grant 60-day extensions to companies whose SAM registrations expire between March 19 and May 17, 2020.  For example, if your registration is scheduled to expire on April 1, 2020, you now have until May 28, 2020 to renew.   You need not take any other additional action at this time.

GSA estimates that more than 60,000 registrations will benefit from this extension.  GSA will continue to process renewals throughout the coming months in hopes of keeping the system moving, allowing your Government customers to pay you. 

Over the past two decades, Coley has assisted hundreds of customers on all manner of Federal contracting issues, including creating and renewing registrations and its predecessor, CCR.  We have continuously kept you informed of all changes that could affect your government business, including, and will continue to do so through the current COVID-19 emergency, and in the future, just as we always have.  When it comes time to renew your registration, you know that Coley will be there.

Families First Coronavirus Response Act- What does it Mean for Your Business?

Families First Coronavirus Response Act- What does it Mean for Your Business?

As part of the national response to the COVID 19 virus pandemic, President Trump signed “The Families First Coronavirus Response Act” (HR 6201), a new law that expands the “Family and Medical Leave Act” (FMLA)  to include provisions for employees and their families affected by the coronavirus/COVID 19 pandemic.  These provisions have potentially large impacts on employers and employee compensation.\.

The law specifies the conditions for FMLA leave that apply to employees in the following situations wherein the employee is unable to work (or unable to telework) due to a coronavirus-related need for leave. The conditions are that the employee be:

  1. subject to a Federal, State, or local government-mandated COVID-19 quarantine or isolation order 
  2. advised by a qualified health care provider to self-quarantine related to COVID-19
  3. experiencing COVID-19 symptoms and seeking a medical diagnosis
  4. caring for an individual subject to an order described above
  5. caring for a child whose school or daycare is closed for reasons related to COVID-19; (and no other childcare option is available)
  6. experiencing any other substantially similar condition as specified by the Secretary of Health and Human Services, in consultation with the Secretaries of Labor and Treasury

Under the Act, Companies with less than 500 employees must provide employees up to 12 weeks of job-protected FMLA leave; 2 weeks of the leave may be unpaid and the other 10 weeks must be paid at no less than 2/3 of the employee’s usual rate of pay.  This employee must have been employed for 30 days or more and the leave may be used only where one of the above coronavirus-related situations described above exists. Payments to the employee are limited to $200 per day or $10,000 for the 12 weeks.

Another coronavirus-related situation addressed by this law requires employers with fewer than 500 to allow employees who are sick with COVID 19-related illness up to two weeks of job-protected sick leave with a compensation cap of $511 per day for the employee’s own care.  Compensation would be at the regular rate of pay unless the employee is caring for a family member such as in the conditions outlined above.

Part of the next Coronavirus relief package currently under discussion in Congress are a series of tax credits and deductions or other relief that will be offered to defray the cost of the coronavirus-related leave requirements on small businesses already reeling from the disruptions caused by the pandemic.

For further information, please consult the Department of Labor Wage and Hour Division:

For the past two decades, Coley clients have relied on our experts to keep abreast of any and all legislative and regulatory issues that impact their businesses.  The current pandemic is no exception—we are on duty to support you.

Disaster Assistance for Small Businesses

Disaster Assistance for Small Businesses

Last week we notified you about the Small Business Administration (SBA) would be providing loan support during this time. They have provided Coley with some additional information to support you and any questions you may have regarding SBA’s Disaster Assistance for Small Businesses. Please take a few minutes to review what is being offered in order to help you start your plan of action to get you through these times.

SBA Disaster Loan Assistance Resources

SBA is focused on providing assistance to small businesses impacted by this health emergency with Economic Injury Disaster Loans, counseling, mentoring, and preparedness services across the country. Small businesses can visit Collective resources for this can be found at or en Español, . SBA offers direct loans through its Economic Injury Disaster Loan program. Traditional SBA-backed loans are still available via banks as well. To find an SBA-approved lender, visit SBA staff are still available in your local community to help answer the questions. You can find them at

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

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].

GSA Issues Guide to MAS Modification Transition

GSA Issues Guide to MAS Modification Transition

GSA Schedule holders have been profoundly affected by the transition to one, unified Multiple Award Schedule (MAS), which has occurred in three phases. 

Phase One:

On October 1, 2019, GSA released the single, unified GSA MAS Schedule solicitation, consolidating 24 GSA schedules into one, and reducing the number of Special Item Numbers (SINs) from 900 to 300. 

Phase Two:

January 31, 2020, GSA released a mass modification for current schedule holders to transfer over into the MAS.

Phase Three:

In July 2020, GSA will contact vendors with multiple GSA Schedules to determine their best option for consolidation into one schedule. 

The transition has raised many practical questions, and to address them, GSA issued final MAS Modification guidelines on March 6, 2020 on the GSA Interact forum and the Vendor Support Center (VSC) website.

The MAS guidelines were the result of GSA integrating vendor comments and concerns gathered through a Request for Information (RFI) issued on January 3, 2020.  The guidance addresses the following types of modification:

  • Administrative (contractor information corrections)
  • Addition of products or labor categories
  • Deletion of products or labor categories
  • Pricing (price increases and reductions)
  • Technical modifications (part numbers, product/labor category descriptions)

The MAS Modification Guide shares information and tips for preparing/submitting the following:

  • Administrative Modifications: Unilateral modifications submitted by contractors to keep company information up to date such as: address, email address, Point-of-Contact (POC), Authorized Negotiator, Contract Administrator, or Industrial Funding Fee (IFF) POC.
  • Addition Modifications: Adds products, services, or SINs to a company’s Schedule offerings.
  • Terms and Conditions
  • Novations and Name Change
  • Contract Cancellations.

The guidance also includes new price proposal templates for modifications.  You can download some of templates provided below:



We at Coley stay ahead of the many changes taking place at GSA in order to serve our clients better in the use and management of their GSA Schedule contracts.  While these changes can be confusing, our GSA Schedule experts can demystify the many changes taking place through the MAS consolidation and help you navigate. If you have any questions, reach out to Coley via email at [email protected]

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