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 (or 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:

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’s MAS Consolidation is Here.

GSA’s MAS Consolidation is Here.

The time has come for GSA’s much anticipated MAS Consolidation. Vendors will no longer be identified under their respective schedule numbers (i.e. 00CORP, 70, 84…) but rather be grouped under a single consolidated solicitation.

GSA’s first of many phases kicked off this past Friday with the temporary closing of the eOffer/eMod system for maintenance and updates but will re-open 10/1 at 8AM EST. All potential GSA vendors who were not able to submit their offers this past Friday are now required to follow the requirements of the Consolidation solicitation. For a copy of the solicitation, you can visit GSA’s “Advance Notice” on the following Interact page:

Roll-out for Existing GSA Schedule Holders:

As GSA continues the roll-out of the Consolidation there are a few things for you to consider as an existing GSA Schedule Holder:

  • Mass Modification estimated to be released early FY2020 (Jan. 2020). Be sure to accept the latest terms and conditions of the Consolidated Solicitation to ensure there is no delay in moving your schedule over. More information provided in GSA’s MAS Consolidation FAQ’s.
  • SIN structure will be updated under the new Consolidated solicitation. The new structure will be based on the North American Industry Classification System (NAICS). GSA provided the attached “Legacy SINs to NAICS” spreadsheet. We recommend reviewing your SAM Registration to ensure the applicable NAICS are listed in your SAM profile.
  • If you have multiple GSA schedules, it is important to note that all your schedules under the same DUNS will consolidate. For schedules with different DUNS, those schedules will not be consolidated and will continue to have their own individual requirements.
  • To encourage vendors to accept the mass modification in January and migrate multiple schedules to one, GSA will update the system in July to only display opportunities for new SINs. Until July, GSA has created a mapping of legacy and new SINS in eBuy, so vendors under both SINs will see all opportunities posted on either SIN.

As a potential (new) GSA Vendor it is important to download the Consolidated solicitation and become familiar with the new Offer requirements. Many of the Technical Evaluation factors have changed and provide more options as a substitute for the Open Ratings Report.

We will continue to track the Consolidation process and provide updates along the way. If you have any questions or would like to discuss the Consolidation and how best to position your company for the Consolidation please contact Coley GCS directly at 210-402-6766 or by email at [email protected].

New Online Training Accelerates Small Businesses success in Government Contracting

New Online Training Accelerates Small Businesses success in Government Contracting

Online training series to help small business gain a competitive edge in Federal Government contracting.

San Antonio, TX, September 13, 2019 – Coley GCS, a Government Contracts training and consulting firm, launched a live webinar on how to ”Uncover End-of-year Contract Opportunities”. It was a great success–students received insights, tools and resources to that allowed them to find end-of-year opportunities.

Government agencies are working at a frantic pace to spend their budgets before September 30th and often work until midnight on the 30th to execute product buys. In 2019, various factors including the December-January  government shutdown, and shifting spending priorities impacted spending. These events have put extra pressure on the government to complete their purchases before September 30th.

This Government Contractor Accelerator Training Series is delivered every Tuesday in one-hour segments. Live webinars are scheduled during lunch in order to fit business owners’ busy schedule who want to attend live webinars to benefit from the Q&A and talk to trainers regarding their specific situation or concern.  Webinar recordings are available for participants to review at their own pace after the webinar is finished.

This is not the first time Coley has provided training to help contractors. Coley GCS has provided U.S. Small Business Administration (SBA) sponsored training for the past two years that help small businesses understand how to navigate the world of government contracting. When asked about the success of this training, Nancy Alvarez, Head of the 8(a) Business Development Program for Region VI said,

 “Coley GCS was instrumental in creating and delivering a powerful capacity building curriculum with proven results.  This initiative gave San Antonio small business firm the push they needed to win more than $70 million in contracts this year.  Thank you for your support

Founder and CEO, Jack Coley has found success as both a government contractor himself as well as a consultant to other companies.  “Our desire is to provide quality products and services to that help others find success.”  Coley helps local and national clients competing in the government marketplace with their high-touch, high-integrity consulting services. Jack Coley explains: “Our team has many years of experience and we wanted to bring that knowledge to small businesses to help them accelerate their entry into the Government contracting market.”

Below is the scheduled for the live webinar for the following 3 weeks.  All Events are Tuesdays at noon CST.

Sign up to our online school and get notices of upcoming training  or enroll to attend any of the Live webinar’s below.

Date                           Course Name:

Coley GCS clients under our annual management program will receive a discount to participate. Please contact your dedicated contract adviser.

Feel free to reach out to us directly if you have any questions at 210-402-6766.

$5 Billion in New Opportunities with the VA for SDVOSBs

$5 Billion in New Opportunities with the VA for SDVOSBs

The Department of Veterans Affairs (VA) Office of General Counsel overturned the VA’s previous determination that VETS First and Rule of Two did not apply to purchases under the $10,000 micropurchase threshold.  The Office of the General Counsel in fact determined that VA micropurchases also fall under the Vets First and Rule of Two, which opens up an additional $5 billion in business to Service Disabled Veteran Owned Businesses (SDVOSBs). This is especially good news for SDVOSBs that sell products, which are frequently purchased under the micropurchases program.

This follows on the case of PDS Consultants, Inc. v U.S. (Federal Circuit 2018), decided October 17, 2018.  The court determined that the Veterans Benefits, Health Care, and Information Technology Act of 2006, commonly called “VBA,” takes precedence over any other Federally established procurement requirements when applied to purchases by the VA.    

The VA Office of Legal Counsel made a determination that the court’s decision and the legislative requirements applies to all VA purchases, including those under the $10,000 micropurchase threshold.

Five weeks remain of the government’s fiscal year and during the final month many purchases using the Government Purchase Card are made. Therefore, if you haven’t already, now is time to make a final marketing push to VA customers and contracting officers.

As a Veteran-owned Small Business ourselves, Coley GCS takes great pride in our ability to assist other Veterans in selling to the VA.  Also, this legal determination opens new doors for Veteran-owned small businesses, let us know if you want our help. You can reach us via email at [email protected] or directly by phone at 210-402-6766.

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]

Supreme Court Upholds Protection For Government Contractors In FOIA Requests

Supreme Court Upholds Protection For Government Contractors In FOIA Requests

Good news for companies receiving FOIA requests for release of information.  The Supreme Court carefully and narrowly defined what information can be deemed “confidential” and thus withheld or redacted from release.

On June 24, in a 6-2-1 decision, the U.S. Supreme Court strongly upheld the protection of Government contractor’s propriety and confidential information with respect to Freedom of Information Act requests to release such information. Since FOIA requests for proposal information are becoming a standard business practice, this strengthens protections of the incumbent or winning proposal submitter against requests. (more…)

New Beta Will Merge 10 Existing GSA Websites

New Beta Will Merge 10 Existing GSA Websites

The GSA’s System for Award Management website ( is looking to make some massive updates in the future. SAM is the searchable federal database where vendors register in order to carry out any business with the government.

The new vision for SAM is to eventually consolidate the functions of 10 existing sites. The goal of this endeavor is to compile all contractor registration and award data into one easily accessible source. (more…)

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…)

Register For the New FAS Sales Reporting System

Register For the New FAS Sales Reporting System

GSA’s Sales Reporting System Open to All

As reported last month and in emails that you may have already received from GSA; GSA’s legacy sales reporting system is being terminated and existing users are being transitioned over to the FAS Sales Reporting System (SRP).

We’re pleased to announce that FAS SRP is now available for registrations.  If you are an active 72a user, this new sales reporting platform is now open for registrations.

Whether you act on this now or later, there is no (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.

Prepare For the New FAS Sales Reporting System

Prepare For the New FAS Sales Reporting System

72A to be Terminated This Year

(May 20, 2019 Update:  Register For the New FAS Sales Reporting System)

As many GSA Schedule contractors are aware by now, GSA will be retiring the 72a Sales Reporting System and will require current users to make a switch to the new FAS Sales Reporting Portal (SRP).  72a is currently being described by GSA as a “legacy” system and will be terminated later this year.

You may have received correspondence from GSA earlier this year about the upcoming transition, however it did not specify the most important questions: when exactly will the transfer occur, how will this be done, and who will have access?

As of yesterday, many contractors are reporting about very specific instruction received regarding the
transition.  All questions have been answered and many concerns have been alleviated.

If you are currently using 72a as the platform to report sales, it is likely this April will be the last time you will be use this legacy system.  For this reporting quarter continue using your standard process: gather your sales by Special Item Numbers awarded against your contract and report via 72a as you normally would.  If you have generated any IFF (Industrial Funding Fee), continue to process payment via 72a as well.  Finally, say farewell to 72a as this would be the last time your going to be using this system.

Mark your calendars!  Sometime in May of this year, you will be able to set up your new FAS SRP
account.  Authorized Negotiators, Contract Administrators, and the listed IFF Representative on your contract will all be able to register.  Be advised that
this system will have implemented GSA’s improved security enhancements
and will not require the use of digital certificates,
however will still be used when submitting modifications and offers to GSA.

After the FAS SRP has been properly set up, your next sales report and IFF remittance will be completed within the FAS SRP for the APR-JUN 2019 quarter.  Sometime after, your historical records will also be migrated from legacy to SRP.

Don’t wait until the next SRP update from GSA!  There are actions that you can do now to help ensure a successful transition to the new sales portal.  We strongly suggest that you review your contracts’ listed points of contact and ensure that all contacts have valid contact information.  If something needs to be adjusted, or new points of contact need to be added, contact your Contracting Officer and submit your modifications now!

As always, we will strive to keep you up to date with the latest updates from GSA.  Please contact us if there’s anything that we can do to help via email or call us directly at 210-402-6766.

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