Source: Winvale – GSA Schedule Blog
If you’ve updated your SAM.gov registration recently, you may have seen a new ownership page. A final rule recently amended the Federal Acquisition Regulations to require all SAM registrants, if owned by another entity, to identify that entity by name, CAGE code, and type of ownership. This SAM.gov rule will provide government insight into 1) Federal spending patterns across corporations, 2) Traceability in tracking performance issues across corporations, 3) Contractor personnel outside the United States, and 4) Supply chain traceability and integrity efforts. As the final rule noted, “Increased transparency and accuracy of procurement data broaden the Government’s ability to implement fraud detection technologies restricting opportunities for mitigating occurrences of fraud, waste, and abuse of taxpayer dollars.”
Ownership is defined as a “Highest-level Owner” and “Immediate Owner”. Ownership is defined as an Entity having ownership or control. And an “Entity” is defined as an Individual, Partnership, Corporation, Joint Venturer, or an Agent. To help respond correctly to this new requirement, we’ve outlined the ownership definitions below.
Highest-level Owner: No entity owns or exercises control of the highest level owner. A highest level owner owns or controls an immediate owner of an entity, or owns or controls one or more entities that control an immediate owner of those specific entities.
Immediate Owner: An immediate owner has at most one highest-level owner. An immediate owner is an entity, other than the offeror, that has direct control of the entity.
Indicators of control can be as follows:
• Ownership or Interlocking Management
• Identity of Interests among Family Members
• Shared Facilities and Equipment
• Common Use of Employees
If you have an owner that fits within the above definitions, they will be required to obtain a DUNS number (from Dun & Bradstreet) and a CAGE Code (from SAM.gov or DLA), and you will need to enter their information within your SAM registration. If you have an international owner, they will need to acquire a NCAGE code. The deadline for this new requirement will be November 1st, 2014.
It is extremely important that your SAM.gov data is accurate, and you don’t make a false misrepresentation and risk corporate exposure for fraud. Should you have any questions, please contact Winvale for assistance.
The General Services Administration (GSA) has requested industry feedback in regards for creating a Cloud Computing Services Special Item Number (SIN) to merge and streamline the way that cloud computing is offered on the GSA IT Schedule 70 contract.
The goal of this change is to improve and make more efficient methods for the GSA to offer cloud computing services to federal agencies. The GSA is striving to advertise and market the growing cloud computing services industry to their customer agencies. This is a great opportunity for vendors in this industry to differentiate their product and service lines from the traditional IT SINs. The GSA’s request for information says, “This effort would support the OMB ‘Cloud First’ policy by enabling agencies to take full advantage of cloud computing benefits to maximize capacity utilization, improve IT flexibility and responsiveness, and minimize cost.”
Cloud computing services are currently being offered under the GSA IT Schedule 70, but under several different SINs. This new proposal will allow these cloud computing services to have their own unique SIN, which will increase efficiency both for the vendors selling the services and for the government agencies looking to purchase the services. The GSA has come to the conclusion that the technology of cloud computing has become mature enough and that it is necessary that it has its own SIN. For more information and to give the GSA feedback, view the RFI on FedBizOpps.
Responses are being accepted until August 6, 2014.
The General Services Administration (GSA) is seeking to better leverage its buying power through Federal Strategic Sourcing Initiatives (FSSI). Currently, the agency is looking into replacing the Office of Personnel Management‘s (OPM) existing Training and Management Assistance (TMA) contract vehicle with a newer vehicle incorporating strategic sourcing principles and OPM’s Human Capital Assessment and Accountability Framework (HCAAF).
The goal is to replace OPM’s existing TMA Human Resources contract vehicle with a contract vehicle that focuses on industry best practices in the fields of human resource training and development and human capital management services. The FSSI is committed to making sure that all agencies are getting value for the tax dollars they consistently pay. Some future solutions include JANSEN, which is a janitorial, and sanitation solution, and Building, Maintenance, and Operations (BMO) solutions. These and other solutions are needed to leverage government spending and thereby increase savings, collect the right data at the right time to drive operational efficiencies and allow for better management decisions, and lastly, to increase the adoption of the best business practices to improve efficiency.
The new initiative could have a big impact on businesses and that is why they are reaching out to the industry for feedback. The information and feedback given to the GSA will be used for preliminary planning and execution. The objective of this feedback is to increase engagement and interaction with GSA’s Industry Partners, OMB, OPM, Army and FSSI HRST Commodity Team stakeholders as they prepare for Phase One in replacing OPM’s Training and Management Assistance (TMA) contract and move to award the FSSI HRST vehicle. The FSSI HRST team is looking for assistance from industry partners throughout the process.
After much deliberation and controversy surrounding the Office Supplies 2 (OS2) contract extension, the General Services Administration (GSA) has decided that it will not extend OS2 contracts. Previously, the GSA found that itself in the forefront of several protests from vendors due to a possible extension. The OS2 contract extension was slated to extend through November and would allow for current vendors to continue their business with government agencies. The main source of the protests came from Coast-to-Coast (CTC) Computer products, which stated that the extension would establish an alliance that would cause hundreds of vendors to lose opportunities to work with the government.
The protests from CTC asked that the Government Accountability Office (GAO) immediately shutdown the OS2 contract extension and that the GSA conduct an assessment on the impact for small businesses.
The following weeks continued with more vendors protesting the OS2 contract extension and House lawmakers becoming involved and requesting impact studies from GAO.
Results arrived as the GSA announced after conducting a thorough review that all Blanket Purchase Agreement (BPA) extensions of OS2 were to end. In addition, all agencies are now required to seek out alternative options until OS2 is properly implemented. The GSA proposed several alternatives such as GSA Schedule 75 and GSA Global Supply through GSA Advantage! Unfortunately, OS2 had allowed for millions of dollars in government savings and the full implementation of OS3 may prove difficult now. GAO recently faced more bid protests for OS3 that were prior to the GSA awarding contracts under OS3, indicating that more post-award protests were expected which will impede OS3’s arrival.
Stay tuned as the following weeks should be interesting for the Office Supply generation vendors and consider consulting with experts in this matter to plan for the best route toward OS3.
The Office Supplies 2 Strategic Sourcing Contract, also known as OS2, recently found itself back in the newsroom as the General Services Administration (GSA) suspended governmentwide use of OS2 due to numerous protests from several vendors. The strategic sourcing contract was slated to expire on May 31st, but the GSA continued to make efforts to have it extended through November.
Vendors sent their timely protest to the Government Accountability Office (GAO) which immediately shutdown the extension. Along with the freeze of OS2, all contract performances faced suspension until further notice. The original protest was sent from Coast-to-Coast (CTC) Computer Products, which stated that “these extensions represent newly awarded bridge contracts” which means that these new OS2 contracts would form a sort of alliance causing hundreds of small businesses to lose an opportunity to do business with the government.
As a result, CTC has requested the GSA conduct an “impact assessment” for small businesses with a possible OS2 extension. The protests have also sparked additional requests for GAO to request that the Small Business Administration (SBA) enforce the rules listed under the Small Business Jobs Act and implement a contract consolidation impact study.
Additionally, CTC’s initial protest has sparked over two dozen protests causing House lawmakers to request that GAO to study the impact of the Federal Strategic Sourcing Initiative (FSSI) on small businesses. The suspension is leaving government agencies detached as they must now find alternative options for further office supply purchases. The suspension is unfortunate as OS2’s implementation in 2010 has allowed for $360 million in savings, meaning both government agencies and contractors are losing until this problem is properly assessed and a solution arrives.
There are three routes commercial cloud service providers (CSPs) can take to be compliant with the government’s baseline cloud computing standards, known as the Federal Risk and Authorization Management Program (FedRAMP). Although these three routes lead to the same ultimate goal, they can differ in time to accreditation and also differ in cost.
Route to FedRAMP #1
The first route, and the most common for commercial cloud service providers, is gaining a provisional authority to operate or (ATO) from the FedRAMP Joint Authorization Board (JAB). This board is led by CIO’s at the General Sales Administration (GSA), the Department of Defense (DOD), and the Department of Homeland Security (DOS). In addition to an ATO, a FedRAMP-accredited third-party assessment organization (3PAO) is required to complete this process.
Route to FedRAMP #2
The second route comes as an alternate. Agencies can grant an ATO to a CSP, and other agencies can choose to take advantage of this authority and work with the company as well. 3PAOs also work with agency-issued ATOs and work with both parties to make sure security standards are met.
Route to FedRAMP #3
The third route and least common is the CSP Supplied route. In this route, a CSP can hire a FedRAMP-accredited 3PAO to complete all required documentation, testing and security assessments. Once all these procedures are complete, the information is sent to GSA’s FedRAMP office for verification. Very few companies have taken this route, due to high cost, but it is a good option for companies that cannot or do not want to take advantage of existing federal contracts and do not wish to partner with other CSP’s.
At the FedRAMP Industry Fair on June 4, 2014 the GSA released a table, which outlined the approximate time it took to become compliant with the government’s baseline cloud computing standards. This table broke out the three routes toward compliancy, under the categories JAB P-ATO’s (Joint Authorization Board) (provisional authority to operate), Agency ATO’s, and CSP Supplied. The timeframe can be found below:
- JAB P-ATO’s: 9+ Months
- Agency ATO’s: 4+ Months
- CSP Supplied: 6 Weeks
As you can see, the process to become cloud computing compliant becomes quicker, when more money and more energy is spent trying to achieve it. These three paths give options, and these options are for companies to choose. This enables you to ask yourself, what route will you take?
If you’re a GSA Schedule 70 Contract holder, the following HITSS II presolicitation notice on FedBizOpps.gov may be of interest to you. Request for Proposals (RFPs) will be issued in August 2014 with contract awards beginning in November 2014.
The acquisition strategy for Hybrid Information Technology Services for State (HITSS II) is to award multiple Blanket Purchase Agreements (BPAs) to GSA Schedule 70 holders, who are small and disadvantaged businesses. The BPAs will have a one-year base term with four one-year options. The acquisition will have two tracks. In Track 1 (T1), one BPA will be awarded to an SBA 8(a) contractor and in Track Two (T2), multiple awards will be made to other small and disadvantaged contractors using the order of priority below.
The following priority sequence will be followed for the HITSS II acquisition (T2):
- HUBZone Small Businesses
- Service Disabled Small Businesses
- Woman-owned and Economically Disadvantaged Woman-owned Small Businesses
- Other Small Businesses
The phases of HITSS II acquisition are outlined as:
- PRESOLICITATION PHASE: Present- May 31, 2014
- INDUSTRY AWARENESS & DOWN-SELECT PHASE: June 1, 2014 – July 31, 2014
- SOLICITATION & EVALUATION PHASE: August 1, 2014 – October 31, 2014
- CONTRACT AWARD PHASE: November 1, 2014 – November 30, 2014
The General Services Administration’s (GSA) Management Services Center (MSC) is conducting a two hour GSA Virtual Industry Day on June 9th, 2014 to bring GSA Contractors and Industry Partners up to date on potential changes to the Multiple Award Schedules Program. The event will be centered around six of the 42 GSA Schedules: MOBIS, PES, ENVIRONMENTAL, LANGUAGE, LOGWORLD, CONSOLIDATED but also FABS and AIMS. For more information and to attend the GSA Virtual Industry Day, register with this form: The article discusses a new platform that the General Services Administration (GSA) is rolling out to allow procurement officers to compare many contracting vehicles, STARS, DOD EMALL, GSA Schedules, etc, which GSA Commissioner Tom Sharpe believes will encourage procurement officers to use GSA schedules to procure more of the goods and services that they need, because GSA schedules will offer the most competitive pricing.This is how the GSA would double it’s market share, by being the best option for procurement. I think a lot of companies, particularly small businesses, wonder if acquiring and maintaining a GSA schedule to sell to the Federal government is worth the time and effort, hence the question, “Is a GSA Schedule worth it?” If Tom Sharpe is correct and GSA begins to fulfill the lions share of procurement needs than YES having a GSA schedule would be worth the investment of time, money and resources. Read more in Federal Times’ article: http://www.federaltimes.com/article/20140521/ACQ/305210016/1001
GSA Virtual Industry Day Agenda:
Are you wondering , is a GSA Schedule worth it? Tom Sharpe, who is helping the agency double its market share in two years, would say YES!
The General Services Administration’s (GSA) Management Services Center (MSC) is conducting a two hour GSA Virtual Industry Day on June 9th, 2014 to bring GSA Contractors and Industry Partners up to date on potential changes to the Multiple Award Schedules Program. The event will be centered around six of the 42 GSA Schedules: MOBIS, PES, ENVIRONMENTAL, LANGUAGE, LOGWORLD, CONSOLIDATED but also FABS and AIMS.
For more information and to attend the GSA Virtual Industry Day, register with this form:
The article discusses a new platform that the General Services Administration (GSA) is rolling out to allow procurement officers to compare many contracting vehicles, STARS, DOD EMALL, GSA Schedules, etc, which GSA Commissioner Tom Sharpe believes will encourage procurement officers to use GSA schedules to procure more of the goods and services that they need, because GSA schedules will offer the most competitive pricing.This is how the GSA would double it’s market share, by being the best option for procurement.
I think a lot of companies, particularly small businesses, wonder if acquiring and maintaining a GSA schedule to sell to the Federal government is worth the time and effort, hence the question, “Is a GSA Schedule worth it?” If Tom Sharpe is correct and GSA begins to fulfill the lions share of procurement needs than YES having a GSA schedule would be worth the investment of time, money and resources.
Read more in Federal Times’ article: http://www.federaltimes.com/article/20140521/ACQ/305210016/1001