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Category Archives: Resources and Insight

New GSA SIN Specifically for Cloud Computing Services

cloud computingThe 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.

GSA Seeks Feedback for new Human Resources Contract Vehicle

human resources contractThe 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.

Using QuickBooks to Accurately Report GSA Industrial Funding Fee

industrial funding feeAre you a government contractor using QuickBooks?  Do you struggle with tracking GSA’s Industrial Funding Fee (IFF)?  QuickBooks is not set up to track GSA’s IFF.  However, features within the system can assist in making this task painless.

Let’s first define what GSA’s IFF is.  GSA’s Industrial Funding Fee (IFF) is a fee paid by government contractors to the GSA to cover GSA’s cost of operating the Federal Supply Schedules program.  The fee equals .75% of your total GSA sales (government sales made through a GSA Schedule Contract) and it is paid every quarter to GSA. There are two processes that can be used to accurately report the IFF to GSA.

The first method is to create a report, but building reports within QuickBooks can be difficult.  Once the report is developed, reporting the IFF can take a few minutes.  First, we will look at the method that works for a government contractor reporting on an accrual method under the GSA Schedule Contract.  This method is straightforward but requires updating the report every time a new contract is awarded.  Go to Reports→ Sales by customers’ → Customize Reports → Filters → Name → Select Multiple Names and then select the names of the customers you need to report the IFF on.  Finally, you will want to memorize the report and update it with new customers when new contracts are awarded.

The second method is not as difficult and has worked very well for my company, Winvale, a reseller of IT solutions to federal, state and local governments.  We report our IFF on the cash receipts basis (you are allowed to use this methodunder the accrual method of reporting).  We useour Profit and Loss statement, change it to a cash basis by quarter and export this report to Excel.  Once the report is exported to Excel, we take advantage of the pivot table function and create pivot tables by name and SIN category and we are done!

These reports will work for many of the government contracts but not all.  If you are dealing with a cost reimbursable contract, DCAA requires your accounting system to be compliant with their guidelines found on their website during the pre-award stage of the contract.  While QuickBooks alone is not DCAA compliant, together with integrated time capture and reporting tools, it can be DCAA compliant. Intuit does not offer any products to make QuickBooks DCAA compliant. However, there are some third party tools and resources available on the internet that can be researched and explored to determine best appropriate tool to make QuickBooks DCAA compliant.

If you are diligent and put in the necessary effort, you may find that your QuickBooks can be adapted for all types of government contracts.

 

 

3 Routes for CSPs to FedRAMP

CSPsThere 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:

  1. JAB P-ATO’s: 9+ Months
  2. Agency ATO’s: 4+ Months
  3. 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?

GSA’s Tom Sharpe Discusses Management’s Role in CO Decisions

Tom SharpeFederal News Radio (FNR) held an interview with Tom Sharpe, Commissioner of GSA’s Federal Acquisition Service (FAS), to discuss management supervision of schedule contract activities. The interview provides insight on GSA’s latest Acquisition Policy and Procedure Directive which outlines procedures to improve procurement controls and ensure evaluation processes are fair for all parties involved. Tom Sharpe also talks about GSA’s emphasis on procurement management reviews and training moving forward.

Some details that Tom Sharpe highlights is reinforcing the proper methods for procurement in order to provide more benefits for customers. One of the main goals of the new Acquisition Policy is to save the customers more time and money which has been an continuous goal for the GSA’s FAS. Growing IG concerns have caused the implementation of the new policy as last June, many FAS managers have improperly intervened in potential negotiations for new GSA schedules. Tom Sharpe further emphasized that the role of management is very important in the field of government contracting and stated that he “won’t tolerate improper intervention or improper execution of that role” The instructional guidance portion of the training portion emphasizes the importance of contracting officers to document all forms of communication with any members involved in the GSA scheduling process.

To learn more about the GSA’s new contracting policy, please visit this link.

GSA Cost Savings Launches Dashboard to Share Progress

OS3 Cost SavingsThree months after the GSA released a Request for Proposals (RFP) for the latest version of the office supply contract, OS3, they have created a dashboard to share the benefits of strategically sourced office supplies with the public. The dashboard will be used to share details on pricing and sales using colorful images and graphics (view dashboard).

The dashboard also allows users to filter the data by federal agency, small or large business sales, socio-economic status, and geographical sales statistics. The goal of this site is to show the GSA cost savings that the government is achieving through the strategic sourcing initiative.

As a result, during the past four years “the Federal Strategic Sourcing Initiative Second Generation Office Supplies (OS2) BPA has saved more than $364 million” for taxpayers and the federal government. The goal is that federal agencies will continue to reduce administrative and other costs with OS3 and the dashboard is the tool the GSA has created to display these savings.  Despite the extensive detail the new dashboard offers, much of the OS3 generation is using the tool as a method for targeting the agencies that have displayed high levels of engagement in the OS3 community.

New GSA Disaster Response for FSS Program

disaster responseNew GSA disaster response rule was recently proposed that could ease the process for companies to get supplies and services during a disaster into the hands of those in need. Under the new rule, the General Services Administration would broaden the Federal Supply Schedules (FSS) program to allow more non federal organizations to take advantage of volume pricing and simplified ordering of commercial products and services provided by GSA approved vendors.

According to an April 17th announcement, posted in the Federal Register, the American Red Cross, state and local governments, and other qualified organizations would receive greater access to schedule products and service if they’re being purchased for disaster preparedness or response. Previously, state and local governments and the American Red Cross were allowed to procure from Federal Supply Schedule contracts under specific guidelines, but other eligible organizations that provide disaster preparedness or response services were unable to. Disaster relief organizations should look further into the new announcement as their response services could become included in the expanded FSS program.

Note that companies that hold schedule contracts aren’t required to accept orders placed by state or local governments, the Red Cross, or other qualified organizations under the proposed rule, but now have the ability if they so choose.

This new rule could provide contractors across numerous schedules with much greater demand, especially in the wake of disasters.

GSA Seeks to Improve Industry Relations by Appointing Ombudsman

SAM.gov Cautions Contractors on OpenSSL Heartbleed Vulnerability

SAMAs a result of the newly discovered security bug, Heartbleed, the Department of Homeland Security is working with other agencies to investigate the potential impacts. The security flaw could allow hackers access to sensitive online information, such as usernames and passwords. The recent panic has also driven the System for Award Management (SAM) to send out emails urging contractors to change their Marketing Partner Identification Number (MPIN). The MPIN is a nine character password that is mandatory for each SAM.gov registration.

To update your MPIN, please follow the instructions below:

1. Go to the SAM Homepage: www.SAM.gov.
2. Enter your user ID and password and click the “Log In” button.
3. Select “Register/Update Entity” from the left navigation menu.
4. Select “Complete Registrations” if your registration is active; “Incomplete Registrations” if you are in the process of updating it; or “Inactive Registrations” if your registration has expired.
5. Select your entity’s name from the list or search for it by DUNS number.
6. Select the “Update” button.
7. If you are only updating your MPIN, select “All sections applicable to the registration besides the Purpose of Registration” from the drop down list.
8. Review each page, selecting “Save and Continue” at the bottom until you reach the Business Information page. Here you will see your MPIN, which can be changed by clicking in the MPIN field and updating the value. Select “Save and Continue” to complete.
9. On the IRS consent page, delete and re-enter the taxpayer name so that MPIN field unlocks. When the MPIN field unlocks, enter the updated MPIN information and click “Save and Continue.”
10. Continue through the registration reviewing each page to make sure nothing else needs updated.
11. Please be sure to select “SUBMIT” at the very end of the registration.
12. Your registration update will go to the IRS for Taxpayer Identification Number validation. If you updated other information, it may go to the CAGE Code system as well for validation.
13. When your update becomes active in SAM.gov, you will receive a confirmation e-mail.

Mandatory Disclosure Rule Encouraged Through the FAR Program

Mandatory Disclosure Rule - Brian MillerAn insightful interview with the vice chairman of the National Procurement Fraud Task Force, Brian Miller, revealed that out of the 131 disclosures the GSA received, more than half were eliminated. Miller’s task force was assembled shortly after the mandatory disclosure rule was implemented in December of 2008. Miller’s main motivation for the new rule was to eliminate any chance of being “victimized by a crime or being ripped off by a fraud.”

The program continues to provide transparency between GSA Schedule holders and their government partners as a source to continue business efforts between both partners. Another main purpose of the new program is to recover money to taxpayers that otherwise would have been lost. The GSA processed $38 billion dollars worth of sales in FY2012  meaning that any return to taxpayers would be substantial and make the program already worth the efforts of Miller’s task force.

Miller also reassures returning money back into the pockets of taxpayers, the program’s ability for GSA Schedule holders to offer full disclosure of their business creates a more fortified relationship with the government. The ideology behind the full disclosure benefit is that organizations that are willing to provide full disclosure to the government are “responsible to do business with the federal government,” Miller further stated that “We don’t see any reason to refer the company for suspension and debarment, because they’re doing the right thing in coming to us.”  The benefit of disclosure is becoming more promising as the rule continues to return strengthened relationships and money back to taxpayers.

GSA Schedule holders should continue to embrace the mandatory disclosure rule as part of the Federal Acquisition Regulation (FAR), and can begin by providing time sensitive, factually based documentation. Miller also states that the any updates should be “disclosed as soon as possible.” Learn more about the Miller’s insights on the FAR program and the best methods to engage in full disclosure.

GSA Schedule holders that are unsure about the disclosure rule or whether they are remaining compliant to the FAR rule should also consider consulting with GSA professionals in this matter.

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