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 stopping your contract’s transition from 72a to SRP.  Most of you all will be reporting your GSA sales in July 2019 for the APR-JUN 2019 quarter, therefore take care of this now to avoid any complications for when it’s time to report sales and pay the Industrial Funding Fee.  Registration is short and simple, and therefore you should not have any issues with registrations come July 2019.

Who Should Register?

While the 72a system assigns a single account for each GSA Schedule contract, the FAS SRP allows all Authorized Negotiators currently on contract to register for this new platform. 

It should be noted that FAS SRP has a different set up on how it handles its users.  Once an account has been created by any (or all) Authorized Negotiators listed under the contract, these individuals will also be able to report GSA sales on a monthly/quarterly basis (check your contract’s terms and conditions!).

  • For most of you out there who report on a quarterly basis, you will be using FAS SRP to report sales sometime in July 2019.  Metrics remain unchanged; gather your sales by Special Item Number and report NLT 30 days after each quarter.
  • For contracts who have opted in TDR (Transactional Data Reporting), you may submit monthly sales reports 30 days after the close of every month.  The latest TDR templates, if needed, are also found within FAS SRP.

FAS SRP Does Not Use Digital Certificates

Users of FAS SRP will no longer need to acquire a digital certificate for logging in.  This will save you some upkeep with no reason to acquire digital certificates for other Authorized Negotiators, however, at least one Authorized Negotiator will have to have a valid digital certificate in order to access GSA eMod.

Sales Reporting Points of Contact

While all Authorized Negotiators will have the ability to create user accounts, this action will realistically go to your accountant or controller.  This user set up is possible, therefore it is best to ensure that these individuals are added on the contract via contract modification.

FAS SRP Additional Features for All Users

I would still recommend that all or most of your Authorized Negotiators register in FAS SRP, regardless if they will be reporting or not.  The system itself has some great features embedded within that all users can access.  You should have no problems in finding out your Procurement Contracting Officer, your Administrative GSA Representative, or even your Industrial Operations Analyst.  You may also view pertinent details about your GSA Schedule contract such as evaluating your GSA Schedule’s *past sales performance, finding your contract value, etc.  And lastly, best to have a backup contact just in case your primary reporting contact is not available.

Transitioning Still in Progress

Once registration has been completed, log in and look around.  While you most likely will not be reporting this second, you can find out some useful contract details without having to go to the Vendor Support Center or any other backdoor link you may have found at GSA.

*Be advised that 72a transitioning is still in progress.  You may not see your past GSA sales history just yet, however GSA has announced that past sales history will be imported into the new FAS SRP sometime soon.  At a minimum, you should be able to see your GSA Schedule contract number on the home screen.

How to Register into FAS SRP:

Transitioning to new Government systems, or being introduced to a new Government system, can be a bit daunting at first; it always is.  However, after going through the registration, I’m pleased to say that this process was as easy as it can be and very surprised.  Hopefully we can all see similar improvements in other systems that are used during contract performance (Schedules Input Program, I’m looking at you).  Hats off to GSA on this one!

When it comes to notifications, however, there have been emails sent out in error.  You may have received a sales reporting delinquency notification and/or an email stating that your contract has/has not meet the minimum sales requirements.  Not what I would regularly suggest but take these sales-related emails with a grain of salt!  Double check to ensure that you have reported sales for the last quarter and assess your past sales to ensure if you have met GSA’s sales and reporting requirements.

GSA is still currently using its multi-factor security procedures currently being embedded in other systems.  Nothing wrong with adding a bit more security to your accounts, especially in this day in age.  When you follow the FAS SRP Registration instruction below, be sure to save your details and your 12-character password (I know) in a safe and secure location.

Here’s How to Register:

  • Go to (FAS SRP Home page)
  • Click on the Registration Link and click the “Submit” button
  • Enter your First Name, Middle Name (optional), Last Name, and email address (match the Authorized Negotiator details as awarded on contract).  Click “Submit” to continue.
  • Your next screen will detail the registration’s “Success”.
  • An email will be sent to complete the account registration.  And within this email, you will see an “Activate Your Account” link that will expire in 7 days.
  • After clicking the activation link, you will then be taken to an additional site to create the following:
    • Password and its Requirements (minimum of 12 characters and must include; a lowercase letter, an uppercase letter, a number, a symbol, no parts of your username, does not include your first or last name).
    • Selection of a Security Question and Answer
    • Selection of an additional Security Image.  This image will display every time you attempt to login to FAS SRP (You know you want to select that cool robot).
  • Click “Create Account”
  • To authenticate your account, click “send Email”, you will be sent an Access Code to your email that you used to register.
  • Once received via email, enter the code in the designated area and click “Verify”
  • After you have verified the access code, you will be taken back to the FAS SRP login site.
  • Attempt to log into the FAS SRP with your newly created account and credentials.  You should be able to see your contract number on the home page.

If you are a Coley client under the contract management support services, your dedicated consultant will continue to handle the sales reporting appropriately during the transition. If you handle your own reporting and are unsure of the system you are supposed to use, visit this GSA Vendor Support Center Tool to find out.

Contact Coley GCS directly at 210-402-6766 if you have additional questions about this process or if you need other GSA Schedule help.

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.

Second Generation IT BPA out on eBuy

Second Generation IT BPA out on eBuy

Information Technology Government Opportunity Released!

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

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

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

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

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

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

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

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

Most frequently ordered manufacturers include:

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

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

Is it Now Easier to Enter the Professional Services Schedule?

Is it Now Easier to Enter the Professional Services Schedule?

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

TXMAS Temporarily Suspending New Offers

TXMAS Temporarily Suspending New Offers

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

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

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

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

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

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

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

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

What A Government Shutdown Means for Contractors

What A Government Shutdown Means for Contractors

While our executive and legislative branches are at a stalemate over budget priorities non-essential government actives will not be funded and as January 20th will usher in a new demographic break-out of party partisans; it is likely this issue will not be resolved quickly. 

How will the shutdown affect you, the government contractor and your employees? The agencies where funding for FY19 has already been passed, and therefore not affected by a shutdown, include the Departments of Defense, Labor, Energy, Health and Human Services, Education, Veterans Affairs and the legislative branch. Your contracts will continue forward, If you have any contracts with agencies controlling discretionary spending — VA, DOD, HHS, Labor, Education or Labor.  You will receive payments for work completed during this time and no contracts should be cancelled.

Agencies impacted during the shutdown include the Departments of Homeland Security, Agriculture, Interior, Treasury, State, Housing and Urban Development, NASA, Transportation, Commerce, and Justice. If you have contracts with these agencies, unless your contract functions are essential, you are unlikely permitted to continue work and you and your employees will not receive compensation for this downtime. Essential personnel, such as airport security, will be permitted to work, however compensation for work may not occur until the government re-opens. 

If you have any outstanding invoices for non-essential work, you will not likely receive payment until the government re-opens. If this effects your business or you feel the issues of the stalemate or more important than your contracts, contact you representatives and share your opinion (technically, they work for us):

US House of Representatives:

US Senate:

White House:

If you have any questions on future or current government contracting opportunities, contact Coley for support.

GSA Releases Plan for One Schedule

GSA Releases Plan for One Schedule

The General Services Administration has announced the consolidation of the 24 Multiple Award Schedules into one single products and services Schedule. This single Schedule will have only one set of terms and conditions, which will allow more consistency in contracting practices. (more…)

Consolidation of the HACS SINs. What you need to know!

Consolidation of the HACS SINs. What you need to know!

GSA IT Schedule 70 HACS SINs

During today’s GSAs Interact Webinar for the new stand-alone Highly Adaptive Cybersecurity Services (HACS) SIN 132-45, plans were discussed with industry detailing best practices for the upcoming Schedule 70 Solicitation Refresh. With this upcoming refresh, currents SINs 132-45A, 132-45B, 132-45C, & 132-45D will be deleted in their entirety and reclassified as a subcategory under SIN 132-45. Along with this new structure, GSA discussed a new “fifth” subcategory and what to do as a current and prospective HACS vendor.

5 Subcategories

  • 132-45A – Penetration Testing
  • 132-45B – Incident response
  • 132-45C – Cyber Hunt
  • 132-45D – Risk and Vulnerability Assessments (RVA)
  • High Value Assets (HVA) Assessments (New Subcategory)

With the migration of the HACS SINs to subcategories, GSA will be adding a fifth subcategory (not previously available on GSA). The new subcategory, High Value Asset Assessments, encompasses a company’s ability to provide Security Architecture Review (SAR) and Systems Security Engineering (SSE). If you believe you qualify for this new subcategory, GSA has identified two group: Vendors with all Currents HACS SINS and Vendors with one or three HACS SINs.

For vendors with all current HACS SINs (132-45A thru D), GSA is accepting a “Service Self-Attestation” acknowledging the company’s capability to perform these services. GSA will be providing a template of the attestation so if you are a vendor with all current HACS SINs, be on the lookout for the template to be released in the solicitation refresh documents. You will have to submit the request through eMod (after the refresh and bilateral modification has been accepted) but the entire mod evaluation process will not be necessary.  For vendors with only a few of the HACS SINs, the Service Self-Attestation will not be accepted. Those vendors will be required to go through the evaluation process including the Oral Technical evaluation to add each additional subcategory.

Modification Process:

As of now, GSA has recommended that all mods be postponed until these changes have been implemented, however, GSA is still accepting and processing modifications based on the current solicitation. GSA has not established a cutoff date but as the refresh nears, GSA will be closing the window for accepting mods based on the current solicitation. So, if you have already submitted a mod or have been working on a mod to add the HACS SINs, be sure to work with your contracting officer to process the mod in a timely manner. BE RESPONSIVE to any clarifications to ensure the mod is awarded prior to the refresh.

What This Migration Does In Ebuy:

With the migration of all the HACS SINs under one SIN, vendors previously not able to see SIN specific RFQ’s will now be able to see all available opportunities under 132-45. However, if you are vendor with only a few subcategories, you still may not be eligible to submit a bid. Agencies will now have the responsibility of clearly stating the subcategory(ies) they are looking to compete. You can help those agencies understand these new changes by providing responses during the “Request for Information (RFI)” stage to ensure your subcategory is identified in the Scope of Work.

When To Expect These Changes:

GSA has a tentative release date of Winter 2018-2019.

Additional Resources

Visit GSA Interact for the Presentation and Draft documents: GSA IT Schedule 70 Program to Incorporate Highly Adaptive Cybersecurity Services (SIN 132-45)

If your company offers cybersecurity and is impacted by this update, contact Coley to help with your modification. You can reach us directly at 210-402-6766 or [email protected].

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