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.    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 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 coleylearning.us/fedmap.

GSA Provides 60-Day SAM.gov Extension

GSA Provides 60-Day SAM.gov Extension

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.

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. 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:

  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:

https://www.dol.gov/agencies/whd/pandemic/ffcra-employer-paid-leave

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 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.

Is COVID-19 Causing You Government Contract Delays?

Is COVID-19 Causing You Government Contract Delays?

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

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

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

Excusable Delays

FAR 52.249 – 14

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

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

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

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

 Suspension of Work 

FAR 52.242-14

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

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

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

(Get full Suspension of Work clause here)

Stop-Work Order

FAR 52.242-15 

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

(1) Cancel the stop-work order; or

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

(Get full clause here)

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

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

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:

SAMPLES:

TEMPLATES:

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 – AMA with Coley GCS

MAS Consolidation – AMA with Coley GCS

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.

 

Ask Me Anything Session from February 4th.

 

Guide to Prepare for Mass Modifications

Guide to Prepare for Mass Modifications

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

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

Before You Sign the Mass Modification

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

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

While Signing the Mass Mod

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

After you Sign the Mass Mod

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

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

For a complete MASS Mod Timeline see below:

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

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

MAS Consolidation Updates

MAS Consolidation Updates

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

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

PHASE II – Accepting MAS Solicitation

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

PHASE III – Consolidating Legacy Contract to the MAS Contract>

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

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

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

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

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

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

GSA MAS Consolidation Mass Modifications Scheduled for January 31, 2020

GSA MAS Consolidation Mass Modifications Scheduled for January 31, 2020

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

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

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

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

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

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

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

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

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

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

DUNS Is Leaving

DUNS Is Leaving

GSA announced earlier this year they would be moving away from the proprietary Dun & Bradstreet’s Data Universal Numbering System (DUNS) in favor of an internally developed and managed Unique Entity Identifier (UEI).

GSA has been extracting itself from commercial proprietary handcuffs over the years, beginning with the Open Ratings requirement, which is now only necessary when a company lacks sufficient CPARS. These moves provide GSA with greater control across all agencies and will allow vendors to compete to provide the entity validation services, rather than provide a direct award to D&B. GSA’s plan is to phase the release of the UEI through December 2020.

Beginning December 2020, Federal contractors will obtain UEI through beta.sam.gov (or sam.gov by that time) registrations and annual maintenance. The new UEI will be twelve characters long and assigned based to separate legal entities or separate physical addresses. All contractors currently registered in SAM will automatically be assigned an UEI by December 2020.

You can learn more at GSA: https://www.gsa.gov/about-us/organization/federal-acquisition-service/office-of-systems-management/integrated-award-environment-iae/iae-information-kit/unique-entity-identifier-update

Coley GCS will be following up on this issue. Follow our blog for future updates.

D&B No Longer Accepting Orders for Open Ratings Past Performance Reports – Now What?

D&B No Longer Accepting Orders for Open Ratings Past Performance Reports – Now What?

When submitting a GSA Schedule Offer, GSA requires that you provide evidence of successful past performance. Typically, this requirement has been satisfied by ordering an Open Ratings Past Performance Report through D&B. However, as of Dec 6, 2019, D&B is no longer accepting orders for their Open Ratings Past Performance Evaluation Report. 

According to the latest Multiple Award Schedule (MAS) Solicitation, GSA permits three options for satisfying past performance requirements: 

Option 1: CPARS (preferred) 

Option one is to verify in eOffer that you have three (3) or more Contractor Performance Assessment Reporting System (“CPARS”) reports that:  

  1. were completed within the last three years,  
  2. represent at least three distinct orders/contracts, and  
  3. outline work similar to the scope of products/services included in the solicitation and for which you are proposing to offer 

Option 2: Open Ratings (NO LONGER AVAILABLE)

This option is not available at this time according to D&B’s website. We will update this blog when the government determines an alternative to the Open Rating report. In the meantime, use Options 1 or 3 to satisfy GSA Schedule Offer past performance requirements. 

Option 3: Past Performance Narrative 

Option three is developing a past performance narrative, which includes a list of relevant customer references. The narrative needs to explain why you cannot use method one or method two, and include up to five (5) references from customers for whom you have performed work within the past three (3) years that is similar in scope to products/services outlined in the solicitation.  

Changes in eBuy During the GSA Consolidation Initiative.

Changes in eBuy During the GSA Consolidation Initiative.

Everything You Thought You Knew About GSA Schedules is Changing.

GSA is rolling 24 GSA Schedules into one Multiple Award Schedule (MAS) that will include 12 large categories, 83 subcategories, and 316 Special Item Numbers SINS. To add to the complexity of this transition, GSA will require Transactional Data Reporting on some SINs, but not on others; and some SINs will include “Special Fees”. With all these changes happening, it can be very challenging to keep up.

The good news is that GSA has thought through the challenges that their consolidation initiative may create and have addressed many of them on its site and in GSA Interact. Ultimately, we believe this transition will benefit both buyers and for vendors; but like most change, it will be painful as we go through the transition.

One question that GSA had not addressed was how they will post opportunities on GSA eBuy where some contracts have transitioned to the new SINs while others are still under the old SINs. Traditionally, the Government buyer (CO/KO) who posts an opportunity to eBuy must select the appropriate SIN. Our concern was whether the Buyer would need to select both the old and new SIN, or would eBuy automatically select both so that vendors would not miss out on opportunities.

We reached out to Stephanie Shutt, Director of the Multiple Award Schedule Program Management Office heading the transition. She reassured us that GSA has developed a mapping system within eBuy that links existing SINs to the new SINs, so all vendors that qualify, whether under the new SIN structure or old SIN structure will receive notice of the opportunities.

That’s great news and reassured us that legacy contractors won’t miss out on posted RFQ’s during the transition. The MAS PMO office is setting a goal to have all legacy contracts transitioned over to the
consolidated MAS no later than July 2020.

All legacy contract holders should receive a mass modification in January 2020 to migrate their contracts to the new consolidated GSA Schedule. Vendors then have six months to work with GSA Procurement Contracting Officers to migrate their contract to the new MAS. There are many things one needs to consider when transitioning, especially where multiple GSA contracts are involved, such as open task orders, contract length, contract terms, discounting policies, etc. 

Coley GCS is already up-to-speed on these challenges and have identified ways to simplify the changes for our clients early in the calendar year. Call us for assistance on the GSA Consolidation initiative—we are ready to help!

You can reach us by email at [email protected] or by phone 210-402-6766.

GSA’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: https://interact.gsa.gov/document/important-advance-notice-gsa-track-debut-consolidated-schedule-solicitation-oct-1-2019

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].

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