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
FSC 4240
N95 masks
4/3/2020
7/1/2020
FSC 6810
Sodium Hypochlorite (bleach)
4/3/2020
7/1/2020
FSC 6840
Disinfectants – includes cleaners, sprays, and wipes
4/3/2020
7/1/2020
FSC 7930
Cleaners – including sanitizing surface and floor cleaners
4/3/2020
7/1/2020
FSC 8520
Hand sanitizers, soaps and dispensers
4/3/2020
7/1/2020
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.
Julio has years of experience helping companies maximize the benefits of GSA Schedule ownership. His expertise spans a broad range of services, including helping companies acquire their GSA Schedule, remaining compliant with the myriad terms and conditions.
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:
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.
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.
Vice President for Coley Government Contracting Services, Dan leads the day-to-day Consulting Practice. He has more than a decade of experience with the acquisition, management, and marketing of Federal, State, and Local government contracts. Daniel specializes in all aspects of GSA Schedules management and marketing and has helped hundreds of Coley clients remain compliant with the terms of their GSA contract while helping them expand their business.
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. https://www.whitehouse.gov/wp-content/uploads/2020/03/M-20-18.pdf
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. https://www.congress.gov/116/bills/hr748/BILLS-116hr748eas.pdf
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 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 coleylearning.us/fedmap.
Jack is CEO of Coley & Associates, Inc. and Coley GCS, LLC. He is an Air Force Veteran, results-driven executive, and successful entrepreneur that thrives in driving innovation and change in and across organizations. Jack has over 25 years of experience in government contracting and uses his expertise to help small businesses accelerate their success in the government market. Jack has advised hundreds of small and large businesses, spoke at conferences, sat on expert panels, and been quoted in numerous articles. His experience spans a broad range of government agencies and functional areas, including information technology, training, logistics, security, medical, and product sales. Jack has helped his clients win more than $3 billion in contract awards, to date.
You probably have many things on your mind right now other than renewing your SAM.gov 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 SAM.gov 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
SAM.gov 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 SAM.gov registrations and its predecessor,
CCR. We have continuously kept you
informed of all changes that could affect your government business, including
SAM.gov, 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.
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. https://www.congress.gov/bill/116th-congress/house-bill/6201/text\.
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:
subject to a Federal, State, or local
government-mandated COVID-19 quarantine or isolation order
advised by a qualified health care
provider to self-quarantine related to COVID-19
experiencing COVID-19 symptoms and
seeking a medical diagnosis
caring for an individual subject to an
order described above
caring for a child whose school or
daycare is closed for reasons related to COVID-19; (and no other childcare
option is available)
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.
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 http://www.sba.gov/disaster. Collective resources for this can be found at usa.gov/coronavirus or en Español, gobierno.usa.gov/coronavirus. . 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.gov/lendermatch. SBA staff are still available in your local community to help answer the questions. You can find them at https://www.sba.gov/funding-programs/disaster-assistance.
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.
“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
acts of God or of the public enemy,
acts of the Government in either its sovereign or contractual capacity,
fires,
floods,
epidemics,
quarantine restrictions,
strikes,
freight embargoes, and
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.
(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
(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.
Vice President for Coley Government Contracting Services, Dan leads the day-to-day Consulting Practice. He has more than a decade of experience with the acquisition, management, and marketing of Federal, State, and Local government contracts. Daniel specializes in all aspects of GSA Schedules management and marketing and has helped hundreds of Coley clients remain compliant with the terms of their GSA contract while helping them expand their business.
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 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]
MAS Consolidation is officially here. Coley GCS will be will providing some insights on what this change means for you in a 30 minute Q&A session to address your concerns during this transition.
Coley GCS has provided GSA Schedule contract acquisition and management support for 20 years.
Since 2001 Coley GCS has helped companies worldwide successfully win and manage more than $1 Billion in Government Contracts. We specialize in GSA Schedules but support any contracting vehicle. We build long term relationships with clients –many who have put their trust in our advice for over a decade.
Review beta.sam.gov and verify that your company has
the appropriate NAICS listed.
Review the terms and conditions
under the Mass Mod (link).
If you take any exceptions to the
standard T&C, you will need to catalog and address them during the mass mod
process.
If you contract is in the process
of being renewed for an option period, speak with your contracting before
accepting the mass modification
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
You must respond to every clause.
A mass mod will need to be
completed for every contract you have on GSA
Your contract number and period of
performance will not change.
The products and services on your
contract will not change.
After you Sign the Mass Mod
Verify your company is visible in
eLibrary under the MAS vehicle
Confirm your that SINs have
migrated
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
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
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.
Vice President for Coley Government Contracting Services, Dan leads the day-to-day Consulting Practice. He has more than a decade of experience with the acquisition, management, and marketing of Federal, State, and Local government contracts. Daniel specializes in all aspects of GSA Schedules management and marketing and has helped hundreds of Coley clients remain compliant with the terms of their GSA contract while helping them expand their business.
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.
Vice President for Coley Government Contracting Services, Dan leads the day-to-day Consulting Practice. He has more than a decade of experience with the acquisition, management, and marketing of Federal, State, and Local government contracts. Daniel specializes in all aspects of GSA Schedules management and marketing and has helped hundreds of Coley clients remain compliant with the terms of their GSA contract while helping them expand their business.
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.
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.
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.
Vice President for Coley Government Contracting Services, Dan leads the day-to-day Consulting Practice. He has more than a decade of experience with the acquisition, management, and marketing of Federal, State, and Local government contracts. Daniel specializes in all aspects of GSA Schedules management and marketing and has helped hundreds of Coley clients remain compliant with the terms of their GSA contract while helping them expand their business.
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.
Vice President for Coley Government Contracting Services, Dan leads the day-to-day Consulting Practice. He has more than a decade of experience with the acquisition, management, and marketing of Federal, State, and Local government contracts. Daniel specializes in all aspects of GSA Schedules management and marketing and has helped hundreds of Coley clients remain compliant with the terms of their GSA contract while helping them expand their business.
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:
were completed within the last three years,
represent at least three distinct orders/contracts, and
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.
Vice President for Coley Government Contracting Services, Dan leads the day-to-day Consulting Practice. He has more than a decade of experience with the acquisition, management, and marketing of Federal, State, and Local government contracts. Daniel specializes in all aspects of GSA Schedules management and marketing and has helped hundreds of Coley clients remain compliant with the terms of their GSA contract while helping them expand their business.
